National Committee on Vital and Health Statistics
Subcommittee on Standards and Security
National Provider Identifier Standards
August 17th, 2004
Lee Ann Stember, President
Phillip D. Scott, Senior Vice President, Healthcare Relations & Development
National Council for Prescription Drug Programs
Mr. Chairman, and members of this committee, my name is Lee Ann Stember, President of the National Council for Prescription Drug Programs (NCPDP). NCPDP is an ANSI Accredited Standards Development Organization whose mission is to create and promote standards for the transfer of data to and from the pharmacy services sector of the healthcare industry. The organization provides a forum and supports its diverse membership to efficiently and effectively develop and maintain these standards through a consensus building process. NCPDP also offers its members resources, including educational opportunities and database services, to better manage their businesses.
In 1991, our membership identified a need for a unique prescriber identifier. Health plans wanted to identify the prescriber for utilization management purposes. Pharmacies and processors or PBMs required a unique prescriber identifier across health plans for prescribing, claims processing, and utilization requirements.
A significant portion of the prescription drug industry uses the DEA number in order to identify prescribers on prescription benefit claims. This is not the intended use of the DEA number, which was created to act as a barrier to illegal controlled substance distribution. The DEA and other agencies would like this number to only be utilized for its intended purpose. The use of the DEA number for strictly financial transactions compromises the integrity of the identifier. Not all prescribers have DEA numbers, other prescribers have multiple DEA numbers, and DEA numbers are assigned to non-prescribing entities such as pharmacies and wholesalers.
As a result of the problematic use and state legislation banning the use of the DEA number for purposes other than originally intended, NCPDP undertook the task of creating an alternative to the use of the DEA number as a prescriber identifier.
In the early 1990s, NCPDP’s Standard Prescriber Identification Number (SPIN) project was formed to solve the problem and work began in conjunction with a large healthcare professional association in 1993. Significant progress was made in the mid 1990s, however, the SPIN project was vacated due to the announcement of the NPI in HIPAA. In response to ongoing requests by NCPDP’s membership to create a solution, and with the delay in the NPI, NCPDP announced the development of HCIdea at its 2002 Annual Conference.
In January of 2002, a contractual agreement was signed with National Health Information Network, NHIN, a database development company, to become NCPDP’s technical partner in developing HCIdea.
HCIdea is an NCPDP prescriber enumeration project wherein all prescribers, even those without the ability to prescribe controlled substances, will be enumerated. It is different from the NPI in that it contains additional fields for each prescriber, which facilitate payment processing and lead to more accurate identification of prescribers.
Ultimately, we envision the HCIdea file to mirror the success of our Pharmacy File. NCPDP’s current pharmacy enumerator, the “NCPDP Pharmacy Provider Number” (formerly the NABP number, which has been in existence since 1977), not only individually enumerates all pharmacies, but also affiliates individual pharmacies with their chain headquarters or payees, if applicable. These additional fields are valuable to PBMs, health plans and pharmacy chains alike in processing claims and providing encounter data to the appropriate entities.
With the eventual implementation of the NPI, NCPDP will create a crosswalk between the HCIdea identifier and the NCPDP Provider ID Number to the NPI, facilitating transition to the NPI within the prescription drug industry.
In order to rapidly and accurately populate the HCIdea database and to gain market acceptance of HCIdea, NCPDP entered into “data supplier” arrangements with various healthcare entities to supply prescriber data to our technical partner for validation and population of the HCIdea database. NHIN receives this data, which is cleansed and each prescriber is then assigned an HCId enumerator. This model continues to provide for ongoing updates of the HCIdea database.
Currently, NCPDP has signed agreements with twelve data suppliers. Multiple data suppliers have passed all certifications, meaning that all criteria have been met and data can flow between the two sources. Several customers are receiving data, one of which is the Department of Defense (DoD), which has entered into a multi-year license agreement.
The State of Utah Bureau of Medicaid Operations, in conjunction with NCPDP and a major pharmacy chain, will embark on the first testing for the transmission of HCIdea data between pharmacies and the Medicaid Bureau in the very near future, with implementation throughout Utah expected during 2005.
NCPDP wants to emphasize that the HCIdea database is not a substitute for the NPI, but a large subset of what will be the providers in the NPS. The current database contains onlyprescribers, including primary prescribers such as MDs and DOs, as well as mid-level practitioners, such as advanced nurse practitioners, physician assistants and others, such as optometrists.
Our best estimate is that our universe of prescribers currently contains 1.2 million records, or in excess of 86%, however we do not yet consider it as a mature product. We are in what we term to be a soft launch phase. But we have made significant strides in a two-year timeframe and have implemented processes that ensure the integrity of the records contained in the database.
The needs identified in 1991 by our membership remain as timely today as they were 13 years ago. The HCIdea identifier not only provides for the claim billing processing initially identified for our industry, but can also serve as an enumerator for the newly defined requirements of electronic prescriptions.
CMS could certainly use the Medicare ID number to identify the prescriber for Medicare Prescription Drug Benefits, however, eprescribing is gradually being adopted by prescribers who serve private pay and Medicaid recipients as well. Using a different number for each payer would add a level of complexity that will impede adoption by prescribers for all types of patients.
Our NCPDP Pharmacy Identifier has been used since 1977. It is included on over 4 billion transactions per year and could be used as a resource for prescribers to identify the community pharmacy of the patient’s choice.
Since the inception of HCIdea, NCPDP has provided information to government agencies and offered our assistance in any way possible. I am here to restate that offer of assistance. Thank you for your time and invitation to speak to you today.
This would conclude our prepared comments. I would welcome any questions that you might have and NCPDP thanks you for the opportunity to present our comments to the committee.