National Committee on Vital & Health Statistics

September 9, 1997

The Honorable Donna Shalala
Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 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 another 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). The NCVHS is very pleased to provide support, advice and consultation to you in this effort.

The NCVHS has been briefed on the proposal for the national standard for identifiers for health plans or PAYERID, and we offer our strong support. The proposal includes a nine digit numeric identifier that would be assigned to all health plans. 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. In the interests of operational efficiency and simplification, we suggest that the Department also leave open the option of moving to an alphanumeric identifier in the future. 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 PAYERID, as proposed, replaces the plan ID and sub ID used in current transactions. The sub ID is currently used for electronic routing, and concern has been expressed that this function will be lost. We recommend that this functionality be addressed before the final rule is issued.

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



Don E. Detmer, M.D.