Checkbook/CSS Response to CMS RFI for a National Directory of Healthcare Providers
CMS’s proposed NDH would provide critical infrastructure to ease burden on providers and insurers and improve accuracy; clear definitions of provider organizations and appropriate accountability are key for success.
Earlier this fall, Centers for Medicare & Medicaid Services (CMS) took an important step toward solving fundamental problems with provider directories by issuing a Request For Information regarding the development of a National Directory of Healthcare Providers (NDH). At Consumers’ Checkbook/Center for the Study of Services, we strongly support this initiative and believe it can dramatically improve the experience of consumers, providers, insurers, and many other health system stakeholders.
For decades, Checkbook has helped consumers choose high-quality providers and health plans. A major blocker for consumers when shopping for healthcare services is the inaccuracy of provider directory data, which often leads to confusion, delays, and even financial harm for patients. One of the fundamental drivers of this inaccuracy is the lack of timely and accurate provider-organization affiliation data.
Health insurance plans generally contract with organizations like medical practices or hospitals rather than individual providers, so in order to determine if a provider is covered by a particular health insurance plan, one most know both which organizations they are affiliated with, and if those organizations have a contract with that health plan. Only the provider organizations know with certainty which providers they have contracts with. At present, however, this is no centralized database where providers and organizations can enter these affiliations and make them available to health plans and the public.
Without reliable affiliation data:
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- Insurers struggle to maintain correct addresses and network status for providers.
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- Patients face uncertainty about whether their provider is in-network.
- Providers bear the burden of updating multiple insurer portals.
Recommendations
1. Prioritize Provider-Organization Affiliation Data
CMS should make capturing and maintaining accurate provider-organization affiliation data the top priority. This single improvement would address many downstream issues in provider directories and network accuracy.
2. Improve Organizational Identifiers
Consistent identifiers for hospitals, sub-organizations, and business entities are essential. At present Type 2 NPIs for these organizations bear little resemblance to the places and entities where patients go to get care. In building an NDH, CMS should improve the structure and assignment of organization identifiers in NPPES and mandate use of public TINs/EINs or equivalent pseudo-identifiers. These improvements, especially in combination with a Consumer Network ID, will align NDH data with insurer contracts and reduce confusion in provider directories.
3. Accountability Across the System
Rules governing the NDH must hold each participant accountable for timely updates. Providers, in particular, should be required to update affiliation data in real-time, or as close to real-time as possible. This approach will reduce stale data and improve consumer trust.
4. Enable Intermediaries and Transparency
Many providers and insurers rely on intermediaries for provider data workflows. CMS should ensure that these intermediaries are able to interact seamlessly interact with the NDH and should set standards for metadata like timing and sources.
5. Open Governance and Usability
NDH development must avoid the pitfalls of NPPES, which has been criticized for poor validation and limited usability. Governance should be transparent, and technical assets like database schemas and data standards should be accessible to all stakeholders—not just those with deep technical expertise.
A high-quality NDH will not only reduce administrative burden but also empower patients to make informed decisions, improve insurer accuracy, and strengthen the overall health system. We welcome continued collaboration with CMS to make this vision a reality.
The full response we sent to CMS is below.
