National Committee on Vital & Health Statistics

June 17, 1998

Health Care Financing Administration
Office of Information Services
Information Technology Investment Management Group
Division of HCFA Enterprise Standards
Room C2-26-17
7500 Security Boulevard
Baltimore, MD 21244-1850
ATTN: John Burke, HCFA-0045

Office of Information and Regulatory Affairs
Office of Management and Budget
Room 10235
New Executive Office Building
Washington, DC 20503
ATTN: Allison Herron Eydt, HCFA Desk Officer

Dear Mr. Burke and Ms. Eydt:

The National Committee on Vital and Health Statistics submits the following comments on the Collection of Information Requirements in the Notice of Proposed Rule Making (NPRM), HCFA-0045-P, National Standard Health Care Provider Identifier.

On the issue of the applicability of the Paperwork Reduction Act of 1995:

The purposes of the Paperwork Reduction Act (PRA) and of the administrative simplification provisions of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) would appear to be extraordinarily compatible. Both seek to minimize paperwork burden and to ensure public benefit. Having a single identifier for health care providers is one of the essential components of administrative simplification, as is devising a straightforward, low-cost method for issuing these identifiers.

We do not believe that the adoption of standards, as required by HIPAA, constitutes an “information collection” in the sense that it is defined under the PRA. The issuance and use of identifiers for health care providers is a usual and customary business activity, which will be simplified by adoption of the National Provider Identifier( NPI). We have made recommendations in our comments on this NPRM that the method of issuing identifiers be carefully limited.

Finally, the PRA regulations (at §1320.18) appear to be clear that the Office of Management and Budget (OMB) has the discretion to apply or not to apply the PRA to the setting of national electronic data interchange (EDI) standards, including the standard for the National Provider Identifier. We urge OMB to follow the intent of both the PRA and HIPAA by not applying the PRA in this instance.

Sincerely,

Don E. Detmer, M.D.
Chair