National Committee on Vital & Health Statistics

JUN 25 1997

The Honorable Donna E. Shalala

Secretary of Health and Human Services

Independence Avenue , S.W.

Washington, D.C. 20201

Dear Secretary Shalala:

On behalf of the National Committee on Vital and Health Statistics (NCVHS),
I am pleased to forward to you our recommendations relating to the first of the
health data standards being proposed for adoption in accordance with the
administrative simplification provisions of the Health Insurance Portability and
Accountability Act of 1996 (HIPAA). HIPAA outlines a new approach to the
adoption of data standards to support electronic data interchange in the health
industry in the United States, in a framework that protects the privacy and
security of health information. The law assigns to you the responsibility for
adopting such standards by February 1998. It also asks you to provide detailed
recommendations to Congress with respect to the privacy of individually
identifiable health information by next August. The NCVHS is very pleased to
provide support, advice and consultation to you in this effort.

To assist in carrying out our advisory responsibilities to you, the NCVHS,
in collaboration with HHS, has held a number of public hearings to obtain input
and advice from throughout the health industry, State government, and the
research and public health communities. The first of the health data standards
to be proposed for adoption is the unique identifier for health providers, which
HHS has had under development for some time and which we understand is planned
for Federal Register publication in July for review and comment.

The NCVHS has been briefed on the proposal for the National Provider
Identifier (NPI), and we offer our strong support. The proposal includes an
eight digit alphanumeric identifier that would be assigned to all providers,
along with essential identifying information. The identifier includes a check
digit and contains no embedded intelligence. We recommend that HHS proceed to
publish the proposal for public comment without delay. While public comments
are likely on the technical details of the number and the optimal approach to
enumeration, we have found broad support for the proposal in general and urge
you to proceed.

The Committee did identify one concern that we bring to your attention. The
NPI, like all of the subsequent standards to be adopted, should be conceived of
as a generic industry-wide standard and it should not contain any requirements
that are specific to individual programs — government programs or otherwise.
It is our understanding that information about HHS Inspector General sanctions
against providers is being considered as part of the NPI system.

We believe that this approach undermines the principle of a generic
industry-wide standard and makes the successful implementation of the first
standard needlessly difficult and controversial. While we are supportive of HHS
efforts to prevent and detect health care fraud and abuse, we strongly recommend
against the inclusion of sanctions information as part of the NPI system itself.
The OIG provider sanctions information is already public, and it can be further
publicized in other ways. We do agree that the use of the NPI to facilitate
access to health care fraud and abuse information in other data systems is both
appropriate and consistent with the intent of the statute.

We appreciate your national leadership in health data standards, electronic
data interchange and privacy, and we are privileged to work with you on these



Don E. Detmer, M.D.