[This Transcript is Unedited]
Department of Health and Human Services
National Committee on Vital and Health Statistics
Subcommittee on Standards and Security
February 23, 2006
Hubert H. Humphrey Building
200 Independence Avenue, SW
Washington, D.C. 20201
CASET Associates, Ltd.
10201 Lee Highway, Suite 180
Fairfax, Virginia 22030
- Jeffrey S. Blair, Co-Chairman
- Harry Reynolds, Co-Chairman
- Justine Carr, M.D.
- Simon P. Cohn, M.D.
- Stan M. Huff, M.D.
- Judith Warren, Ph.D.
TABLE OF CONTENTS
- Call to Order, Welcome and Introductions – Harry
Reynolds, Jeffrey Blair
- Matching Patients to Their Records
- Susan McBride, Ph.D.
- Jac Davies
- David Espey, M.D.
- Sara Temlitz
- John Chlumsky
- Subcommittee Discussion – Jeffrey Blair, Harry
P R O C E E D I N G S [1:21 p.m.]
Agenda Item: Call to Order, Welcome and Introductions
MR. REYNOLDS: Let me call the meeting to order. This is a meeting of the
Subcommittee on Standards and Security of the National Committee on Vital and
Health Statistics. The committee as you all know is the main public advisory
committee to the U.S. Department of Health and Human Services on national
health information policy.
I am Harry Reynolds, co-chairman of the subcommittee and I work for Blue
Cross and Blue Shield of North Carolina. I would like to welcome my co-chair
Jeff Blair, fellow committee members, HHS staff and others. This is a public
meeting and we are broadcasting on the Internet. Is that correct? We are
broadcasting on the Internet. So, please speak clearly into the microphone at
Also, the meeting is being recorded and transcribed. So, I would like to go
around the room and go ahead and do introductions and then we will get into the
MR. BLAIR: Jeff Blair, co-chair, Subcommittee on Standards and Security,
NCVHS. I am the director of health Informatics for Loveless Clinic Foundation
and to the best of my knowledge, I do not have any conflicts of interest.
DR. STEINDEL: Steve Steindel, Centers for Disease Control and prevention,
staff to the subcommittee and liaison to the full committee.
DR. HUFF: Stan Huff with InterMountain Health Care and the University of
Utah in Salt Lake City, member of the committee and of this subcommittee and no
MS. AULD: Vivian Auld, National Library of Medicine, staff to the
DR. FERRER: Jorge Ferrer, VA, staff to the subcommittee.
MS. GOVAN-JENKINS: Wanda Govan-Jenkins, NCHS, staff to the committee.
DR. HUNGATE: Bob Hungate, Physician Patient Partnerships for Health, member
of the NCVHS committee and visitor to the subcommittee.
MS. PICKETT: Donna Pickett, CDC, NCHS, staff to the subcommittee. DR.
WARREN: Judy Warren, University of Kansas School of Nursing, member of the
subcommittee. No conflicts.
MS. FRIEDMAN: Maria Friedman, the Centers for Medicare and Medicaid
Services, lead staff to the subcommittee.
MS. GREENBERG: Marjorie Greenberg, the National Center for Health
Statistics, CDC and executive secretary to the committee.
DR. COHN: Simon Cohn, Kaiser Permanente, chair of the committee and a
member of the subcommittee. No conflicts of interest.
(Introductions around the room.)
Agenda Item: Matching Patients to Their
This is the afternoon of matching patients to their records. So, we have as
one of our key focuses that we have had as a committee and having listened to
David Brailer and others yesterday talking about the architecture going forward
as far as how we do things across the nation, I think it continues to be a very
A member of our committee, Judy Warren, has taken the lead for us on this.
So, without further ado, I am going to turn it over to Judy to introduce our
presenters and we will go from there.
Thank you, Judy.
DR. WARREN: We have arranged this afternoon to talk about matching patients
to their data and I have broken the afternoon up into two panels. The first
panel is from the private sector and we have two people who are going to come
and testify about what they are doing and then after our afternoon break, we
are going to be looking at how various government agencies are addressing the
same issues. So, the first people to come up will be Susan McBride, who is with
the Dallas-Fort Worth Hospital Council and having talked with Susan over the
phone a couple of times, I think you will be really interested in the
presentation that she is going to be making.
We also have another presenter, who will be dialing in after Susan presents
and her name is Jac Davies and she is with the Inland Northwest Health System
in the State of Washington.
So, with that, I would like to turn it over to Susan and have her give her
presentation. I told Susan she has got about 20 minutes or so for her
presentation with questions after that and then we will go on to Jac.
PARTICIPANT: Do we have copies of the presentation?
DR. WARREN: Yes.
DR. MC BRIDE: Some of those slides will overlap into what I am going to
present and that is actually the presentation, I believe, that Donna Pickett
heard me give at the National Association of Data Organizations. So, I am happy
to speak to any of those slides that I don’t cover in my presentation, but I
have just a slightly different plan on things after speaking with Dr. Warren.
So, I will start by introducing myself. I am Susan McBride and I am the
vice president over our data initiative at the Dallas-Fort Worth Hospital
Council and I am going to begin by telling you a little bit about that
organization and how we are managing data and how we are using data and then
where we are headed in the future and what we think the issues are around
patient matching and the master patient index or identifier, unique patient
identifier, whatever acronym you want to use to describe that indicator.
So, let me just by saying that we are a trade association as the
Dallas-Fort Worth Hospital Council. The Education and Research Foundation
houses our data initiative and so we also have a workforce center under that to
address workforce issues within our region, as well as the data initiative and
our disaster planning efforts are also under that Education and Research
Those three entities work very collaboratively. We believe that there is a
lot of overlap between what is happening in the disaster preparedness arena,
especially around syndromic surveillance type data and what we are doing. So, I
will talk just real briefly about that and then if anyone has any questions
about how we see those things interfacing, I will be happy to address that.
We have a data warehouse right now with over 6 million inpatient encounters
that houses our hospitals submission to our public domain data program in the
State of Texas, our Texas Health Care Information Collection, under the
Department of State Health Services. We are the submission agent for our 70
member hospitals and have built a large comprehensive warehouse around that
data set and information. We also have in that warehouse matched hospital
discharge data and birth certificate data with over 400,000 births now over a
five year period on 41 birthing hospitals in our region.
As many of you may or may not be aware, we have Parkland there in our
region that has more births than any hospital in the U.S. Sometimes one of the
Atlanta hospitals tips over us. We have quite a bit of information and data on
our hospital discharge and birth certificate files. That is where we have done
a lot of work around the probablistic linking and algorithmic linking. So, I
will talk a little bit more about that very specific project as an example. I
won’t belabor the technology piece of it because I know after looking at the
transcribed meetings that you have heard a lot about the technical,
methodological matching techniques.
We support a health services research out of this warehouse — health of
populations served and I will tell you a little bit about some of those
projects that also have some of that probablistic linking at the heart of why
we are helping to support the activities.
Outpatient data initiative starts in 2006, where we will be getting
outpatient data for all our hospital members. We have a regional patient safety
and quality collaborative project, the large project we are focused on this
year that we will be addressing as medication reconciliation. We are partnered
with medicine with our county medical societies, as well as the Texas Medical
Association, which has taken medication reconciliation on as one of their three
major projects around patient safety this year. We believe that we will be
working with pharmacists, our hospitals, as well as medicine to address this
We also believe that it will be the foundation for our RHIO activity around
e-prescribing. The CMS quality indicators are routed back to the Dallas-Fort
Worth Hospital Council to all members via our Texas Quality Improvement
Organization. So, all that information is housed in our warehouse to address
primarily patient safety and quality, but what we have found is this
information is a robust house of information for our county public health, for
our community health assessments and our data is quite current.
It is 90 days out from close of quarter, which is certainly not real time
clinical information, which is where we are headed, but it is fairly recent
information that can be used. The AHRQ quality indicators, we were — Texas was
one of the beta states, tested the first quality indicators that went out from
the Agency for Healthcare Research and Quality. We also picked up on the
prevention quality indicators and you will see how we are utilizing those
indicators to address some of our community health assessment and our plans
around how we are addressing the health of our population.
We also run the patient safety indicators as well. Over 70 measures are
housed in our warehouse. We have web-based analytic tools that examine
population trends, quality of patient safety. I am going to run through a few
of those reports. I won’t belabor that.
RHIO activities were initiated in 2005 and I will speak to some of those
activities as well. As you can tell, we started out as the submission agent
through our hospitals, through our public domain initiatives, but our primary
concern was not that submission to the state to meet public domain mandate. It
was to address patient safety and quality and to begin to collect data
regionally in our information.
Those conversations started in the early nineties out of our area. Our
legislation went forward in 1995 and was funded in 1997. So, our region of
state in front of — beginning to use or trying to use data as effectively as
we can, collaboratively among our hospitals. We have recently been funded also
by an NIH grant under AHRQ to push the technology we have created for our urban
hospitals out to 66 rural hospitals. We have approximately 40 hospitals, rural
hospitals, in our warehouse now. So, we have this core of urban, but now we
also in partnership with Texas A&M, the Health Science Center, they are
reaching out to the rural hospitals in the State of Texas. And as you may be
aware, we have quite a few hospitals in the state, primarily the largest
population of our hospitals is rural.
So, we are beginning to look at how well what we are doing is actually
going to work for our rural hospitals in Texas. This is what the interactive
web-based tool looks like and these are the AHRQ patient safety indicators.
What we have done and we are a business associate partner under HIPAA with all
What I want to show you is just this little check right here. This allows
our hospitals to drill through to who is in the numerator population of their
patient safety events. These are all the patient safety indicators and here are
the hospitals. They are sharing this information, using it collaboratively,
trending it over time and then a hospital can actually decide and that is
authorized by our CEOs, who within their infrastructure, quality and patient
safety can access that drill through. It is protected by firewalls and what
they will do is drill through the information, allows them to track trend, look
at things like failure to rescue and what is going on in that patient
population in order to address those concerns.
We are also launching that with our quality indicators, looking at the
mortality within our region in that same manner. What we are doing is trending
all our mortality indicators, our prevention quality indicators and our patient
safety indicators. You can see — and we believe that this is reflective of the
CMS activity around our process measures, around congestive heart failure,
which we are going to begin to get back from our QIO, to put both of these
things, both outcomes and process of care, against each other to see where we
have got opportunity for improvement. Here, we are clearly doing well and we
believe it is reflective of what is going on in the nation around those
congestive heart failure measures, process measures.
If you look at congestive heart failure, using the prevention quality
indicators and these bump up against the denominator population is the census
data. So, this is actually where the patient resides and the admission rates in
that county up against the census. So, this is 2000 data. If you watch the red
counties, you can see that not only have we got CHS mortalities trending
downward, but we have congestive heart failure mortality rates increasing,
which tells us we really need to up our clinic activity around CHS. We need to
manage their medications better, which ties to our patient safety initiative
around medication reconciliation and we actually believe that the congestive
heart failure population may be one we really hone in on and see how effective
we are being with our medication reconciliation project and may look at as an
end point to that intervention, CHS readmission rates across all entities,
which again pulls back in that linking, which we need to be able to do in order
to get to readmission rates across entities.
This is 2001, 2002 and 2003, which you can see those congestive heart
failure admission rates increasing over time. Something else we have been
looking at from a population health standpoint and are very concerned about the
rise in the methasone resistant staph that we are seeing in our region. This is
trending upwards. This is using ICD-9 coding data. So, the preexisting on
admission flags, I am anxious to talk to Donna Pickett about what she is doing
around the guidelines for this activity because what our hospitals are telling
us is that their intention and control programs are indicating that their
nosocomial infections are flat or declining.
So, this is coming in out of the community, we believe, with this incline.
What can we do about this steep rise in the MRSA? One of our esteemed
epidemiologists in our region, Dr. Robert Haley, almost two decades ago wrote
an article, “MRSA, Are We Just Going to Have to Live With It?” We
hope not. So, our region is really wanting to try to take this on in
partnership with public health, to try to create some intervention that will
2006, Patient Safety and Quality Collaborative, I have talked a little bit
about this already. So, I am not going to belabor this since I have quite a bit
to cover here, but we believe one of the things that is clearly a foundation
for any regional health information organization is going to be the security of
privacy piece and that trust of the health care consumer is at the base of any
successful organization in order to be able to share real time clinical
information and effectively use it.
I am going to speak just briefly about that in closing. So, I am not going
to go into that much more.
Patient matching and a master patient identifier, this was what Dr. Warren
asked me to speak about. What are we doing around algorithmic linking and how
effective is it for us and do we believe that it will work for real time
clinical application. So, I know that you have belabored the methodology
points. So, I am not going to necessarily go into too much of that.
Major purposes as we see it, though, we do believe that it is useful for
disease surveillance. You can look at quite a bit linking to other registries,
birth certificate, death certificate, hospital discharge data with all three. I
think Washington State has done some remarkable work around that and there is a
lot of scientific literature around how those data sets can be used to not only
look at disease surveillance but also help services, researchers research
interventions and how effective those interventions are.
Outcome measures, we definitely believe and are using it to look at our
outcome measures in our region, but it also augments data through the linkage,
where you can actually compare data sets, like the birth certificate and the
hospital discharge data. We have done a lot of work in our region around
looking at induction ranks and primary cesarian delivery rates and what is the
effect of inductions on primary cesarian delivery using our linked birth and
hospital discharge data set.
What we know is there is disagreement in what one data set said, was there
an induction or was there not an induction. Cesarian is actually — there is a
lot more agreement on that variable, but you can actually use the data sets to
tease out what is valid and reliable information and when they don’t match with
regards to an intervention or an outcome, what is in that data. Is there a bias
introduced when you don’t have a match?
Yes, we do see bias. So, that is quite a lengthy discussion. I won’t
necessarily go into that. But it is excellent for augmenting looking at
information with a more robust data set. The — linking versus probablistic
linking, we have actually used both methods within our hospital council. It
depends on what we are looking at and why we are looking at it as to whether or
not we go one direction or the other, but we prefer probablistic linkages.
I know you have had a lot presented on the differences between the two. So,
I am not going to necessarily belabor that issue.
MR. BLAIR: Please don’t skip over those. Those are major issues that we are
very interested in and why are you using each one and how did you do it.
DR. MC BRIDE: All right. I do have some slides on that and deterministic is
an exact match. It is created on one or more matching variables between data
files and you want to use a shared unique identifier across the data sets and a
unique ID, theoretically error free and not missing. So, sort of the
fundamental of dynamanagement(?) that most DBAs, database administrators, and
that kind of thing will tell you is that you need a unique key in order to
match two files.
Well, in health care, we very seldom have that unique key. So, we have to
create mechanisms in order to match data and a deterministic link is what you
want to link if you are fairly confident you have got two files that have the
same data in them. And you can use more than one variable to actually link it.
But you have to have consistency in order to use deterministic methods.
What we see in large data sets, particularly in the clinical setting, as
well as our house data warehouse, within the Dallas-Fort Worth Hospital
Council, it is very seldom that there is a unique ID that is error free. So,
probablistic is a method that we typically use. It is a lot more cumbersome.
However, it calculates the likelihood of a correct match, while allowing for
incomplete or error conditions within the records to address those errors.
So, why do we do this? Well, names are abbreviated differently. Nicknames
are used in one data file and not in the other. Two last names may be used.
First name and last name are swapped. You might have misreported dates or parts
of dates that are swapped. You may have missing data in other areas. The
missing data is a big issue. So, when you are using multiple fields and you
have missing data and/or transposed numbers, that introduces challenges with
regard to the linkage.
The Dallas-Fort Worth Hospital Council projects that were currently in
house using these techniques on are the birth certificate data and the hospital
discharge data that we have talked about that we have done for some time now,
over five years of linked data. But we also have quite a few health services
research projects, too, which are NIH funded, a domestic violence project that
is linking our crime data in our Dallas County with the domestic violence
looking at substance abuse and both the perpetrator and the victim to see what
the association is between substance abuse and violence and hospital admissions
with regard to mental health. So, they need us to link the crime file with the
— and we are in the process of developing those probablistic linking methods
right now for that study.
Cardiovascular longitudinal study has been ongoing for about five years
now, where we are in partnership with UT-Southwestern and we are linking the
readmission of a longitudinal cohort that UT-Southwestern is following across I
believe it is ten years, it is a ten year longitudinal study, that is very
similar in design to the major cardiovascular study that was done a number of
This is oversampling of African Americans and we have been doing that, as I
have said, for about four or five years now. Readmission rates for elderly
chronic care condition, there is a proposal out there now for us to look at one
of our major systems and to link their chronic care elderly cases across all of
our hospitals with regard to admission and they want to create some
interventions and then try to address some of their elderly chronic care
conditions and we believe that this may be the model that we can use for our
entire community to address our medication reconciliation and those endpoint
measurements that I talked about potentially around congestive heart failure.
An evolving project is the tracking of MRSA patients across health care
delivery systems as a region, working to create an effective community
intervention. So, we are going to be looking to link some of those methasone
resistant staph cases and see whether or not we are going to work with some of
our sociology, demography type experts within our community and research
colleagues, to look at whether or not we have pods of MRSA generated out of a
certain region in our territory.
Linking in and out patient delivery will be deployed in 2006 as well. So,
an example of matching projects to go into what Mr. Blair requested, we are
taking the birth certificate and the hospital discharge data and linking it. We
are also adding in the American Hospital Association data and we have linked
historically a neonatal survey on what is the level of NICU that these
The steps to the matching, the first step is to parse the data into fields
that can be standardized. So, there is a lot of data management around doing
this and it can be automated, where your code is capped and you run it against
the same data set and actually we are working to automate this process right
The step 2 is we use a tool called — that MatchWare Technologies actually
created in 1998. Dr. Jarrow(?) did some of the really solid work around
probablistic matching and created the tool and what we heard from public health
at a recent conference that we attended, that this DOS-based auto stand, 4.7,
is still what a lot of our public health departments are using. They get a
better match than some of the more sophisticated tools, using this DOS-based
system and its original algorithms that are built into it. One of the things we
are going to actually do is very cumbersome. We are going to test some of the
other tools that are out there against this old DOS-based tool to see whether
or not we are getting as adequate a match on our birth certificate and hospital
So, we used the auto stand tool to actually, once we parse the data to
standardize the data and I am going to talk a little bit more about that, but
it standardizes such things as a-v-e-n-u-e, avenue and a-v-e or street and
abbreviations of street.
The program actually maps these terms into one standard term. So, then it
assigns fields and probabilities or the researcher does. We have actually
standardized how we are doing this. So, all of this is read pretty routinely,
these pieces of it. Once you establish what your probabilities are, it is a
fairly standardized process. What you decide is what the allowable error is,
within the fields or the variables that will be matched.
Then the match processes run with auto match 4.2, which is the tool that
actually came out in 1998, alongside the 4.7 auto stand. What it does is
actually an iterative block that matches the data. I am going to talk a little
bit more about that blocking so I won’t go into that now. But this is what this
looks like, as far as the matching process. This is what we do. We do it to get
the comprehensive file that has over 250 variables in it.
Hospital discharge data is this is the mother’s record. You have got the
birth certificate data, baby’s record. You run auto stand against it and it
standardizes the file of the mother’s record and it standardizes the file of
the baby’s record. Then what you do is run auto match against that linking the
two with — and that is matched with auto match based on that standardization
So, then what we also do is we take and run a sequel run against the data
that actually takes tags of ICD-9s with comorbidities. So, we can actually look
at whether or not the mother had diabetes or whether or not there were birth
defects present and that kind of thing. So, we also have a hospital discharge
risk factor file that we merge with that file. We merge the AHA survey data
with the hospital characteristics in it and then the final file contains three
distinct files, all merged together with the mother’s hospital discharge data
flagged with risk factors and the baby’s birth certificate data in the AHA
hospital survey data.
We have roughly anywhere from a 93 to 95 percent match rate depending on
the year. A lot of our mismatches are multiple births, where we match on the
first baby and so we have been challenged with what the right thing to do with
multiple gestation is and depending on what the purpose of that data is being
used for, as far as research studies, they may or may not need access to the
twins or triplets, that kind of thing. So, a 93 percent match is a pretty good
match rate for birth certificate and hospital discharge data compared to a lot
of the public health programs that are out there matching, such as Washington
State, who has done this for a number of years.
Their match rate hovers around I believe 93 to 95 percent match as well.
This is the probablistic linking where you block one and then you block two and
the reason — I am going to talk a little bit about the blocking, but I want
you to know the dependency on the social security number here. Any of your good
solid match rates, such as hovering around the 95 percent, we are dependent on
the social security number or some unique number that has been established
within a state and there are states that have not relied so heavily on social,
but speaking with NADO recently, what we understand is that is not the norm.
The norm is that most public domain programs and their public health
departments are relying very heavily on the social security number for these
types of matches.
If you don’t have it, your match is very poor and I think that some of the
other speakers spoke to that and actually have done more investigation into how
poor it really is in a very scientific manner. So, I was really happy to see
that evidence because we knew from our experience that social, when you don’t
have it, it is very problematic. So, that was an excellent presentation on the
flaws within probablistic linking when you don’t have the social security
The automated and use of blocking, suppose there are a hundred birth
records and a hundred hospital records with a one to one match in the other
file. You compare every record in each pile with every record in the other
pile. It is sort of a simplistic way of looking at it. So, 10,000 comparisons
for a hundred matches manually is really impractical and inefficient. So, what
the blocking in matching actually does is it is a run of data that is much more
efficient. So, the picture that I hope you are getting is a lot of data
processing to do this.
So, one of the things that the blocking does is to break these files down
so it is a lot more efficient run and computing power now, thankfully, has
gotten very cheap. So, the processing isn’t such a huge issue, but when you
talk in terms of the nation, you know, I can’t imagine how this must be for CMS
or something like that, which I believe you are going to hear from a little
bit. So, it will be interesting.
But, again, computing power is cheap. The technology is — we don’t
believe. Comparing records, I already kind of covered that. Multiple passes,
what happens if the record is miscoded for months. The record will never be
compared with that matching record and the solution is those multiple blocking
schemes and looking at different schemes to actually match on that.
The typical steps in the methodology are you press the data to match in the
software. Auto match intakes an ASCII file. It is that old DOS-based file. This
is what I meant when I said it is very cumbersome. The codes 2000 actually uses
an access database, which is the more recent versions of this type of tool. The
data format standardization to make the data element formats the same in the
data sets matched, as I have talked about before, as far as the standardization
and you have the parsing of the names and the addresses.
So, why standardize and parse? I think this, too, was covered, but
alternate spellings and Dr. William J. Smith, Bill Smith, W. John Smith, these
are examples of how many more combinations might be possible that we could sit
here and play with out of these names. It would be tremendous.
So, what does this look like? Well, this is an example of 487 North
McKinney Avenue. So, when you parse, you split that into No. 487 and a modifier
of avenue. Then the direction is north. So, what you then get out of your
standardization tool, which I have talked about is this is where you cover the
a-v-e and you would need the Fort Worth spelled out and you cover the
misspellings or the possible types of spellings that you might see.
So, then as far as identifying comparison strategies with blocking
matching, which variables to compare, which initial rates, all those things
have to be decided. So, one of the things I hope you get out of all of this is
the lack of — it is really almost an art more than a science in how we are
doing this. So, the lack of standard and, you know, how good is the science or
the data manipulator behind this process is really important when you start
using these tools.
So, you prepare the matched specification files, both by data dictionaries,
the blocking variables for each pass, the matching variables and once all this
is done, it is a fairly routine process and we are going to move it to the next
step this year where there is not so much interaction with a human being. We
are going to move it more to an automated process.
Let’s see, I have talked about estimated weights. Weights are automatically
assigned for each of the variables being compared by the software that you plug
in and decide upon and then a pointer is sized to the matched cases. The cases
for clerical review are reviewed clerically. So, when you mismatch, what do you
do with those and how do you introduce bias? We review those quite a bit to see
what has been introduced, depending on the use of the file, use cases of what
the request is as far as access to the data.
The matched cases are not considered in future passes. So, those are set
aside. But once again we don’t just set aside without looking to see what are
in those mismatched cases. The process is repeated for all the passes. Once
again, I am just sort of showing you the picture once I have talked about
blocking and matching of what our process looks like and the weights that we
have established on the key fields that we are matching on.
Let me just review them real quickly. We use a hospital D from the birth
certificate data. We use the year, the month, the day. Social security number
is a heavy dependency here and then, of course, the mom’s residence, where she
actually lives and that pretty much — the date of birth is another component.
So, the final result, we have a merged database with mother/baby match.
We have AHA hospital characteristics linked to the unique providers and the
ICD-9 flags that I have talked about that are the risk factors within the file
and the result is a very robust file of 250 variables. Our public health
department is very interested that automating this as quickly as possible and
getting that information back out to them because unfortunately our Texas
Department of State Health Services data management budget has been cut so
short that they actually do this work themselves.
Our legislation around our public domain program right now creates issues
for us with regards to linking some of these data sets and we hope to address
that in the 2007 legislative session for Texas. Hardware and software
requirements again, modern hardware exceeds virtually all requirements. So,
that we do not see an issue, have not in the past, don’t in the future.
Software options are limited and this — at the public health conference
that we recently talked about where several of us were together talking about
how we are managing this process, we talked about the fact that the options —
there are government options out there, academic and commercial. The software
commercially ranked is from 5,000 to 200,000 and the 5,000 are those of us that
bought into this DOS-based program years and years ago. That is approximately
what we paid for that fee for DOS-based.
So, monetarily is definitely one of the reasons we are still hanging onto
that old DOS-based tool, but what we also have heard is that some of those
Windows-based applications, they are a little bit more sophisticated, don’t
work as well. So, what we really would like to see and we called for AHRQ at a
recent conference to consider maybe some fact standardized code if we are going
to continue to do this kind of thing and we believe that we will have —
regardless of whether we move with the National Patient Identifier, there is
always going to be a need to do this kind of thing for many, many years to
So, we really do need a standard mechanism for doing that and we would love
to see like they have developed the AHRQ quality indicators some software text
that would describe how one would map some of these standardized data sets in
and then some south(?) code developed potentially that would standardize the
way that we are doing these things across the United States.
I hope AHRQ or someone is considering that out there. There is definitely a
learning curve with it and I think what we have seen with these quality
indicators is that we are going through that curve together and learning how to
standardize on using those tools together across the nation and sharing with
each other how to effectively use them and I would see if doing something like
this in a similar way.
So, what are the issues? Probablistic linkage versus deterministic,
algorithmic linkage — and I am using those probablistic linking is an
algorithm that you use. It contains error, even though probablistic is one of
our better methods for doing that, it still contains error. Recently, when I
talked to a gentleman by the name of D. Hock, who founded the V-Surp(?)
Corporation. What he said to me was very interesting. When I was talking about
this whole challenge that we have, he said would you be okay with me getting
your Visa card charge right 95 percent of the time? So, you know, and he said
you are talking about my health care information.
So, that was just really — I had the opportunity to speak with him two
days ago prior to coming in here because one of my colleagues said you are
going out there to talk about this. You really need to talk to this gentleman
first. So, he shared with me just an amazing story of how Visa had established
trust and they do have a unique ID number and they are very confident that when
I put a charge out there electronically, it is secure. It is private. The
transaction occurs and the public trusts that.
So, what did they do to establish that trust? I know that you all have
talked about looking at the credit card industry. He has a fascinating story to
tell in his book. One to Many, I believe, is the name of the book and I
am about halfway through it right now. We are going to look at that as our
regional health information organization in our regions and see whether or not
there is anything we can pick up on in order to address this issue because we
don’t think algorithmic linking will work, not for our clinical care. It is not
We know that the privacy concerns are huge and that is where I think
regionally we can really regionally we can really partner and get into our
communities and educate the public. I don’t know how yet we establish that
trust or the infrastructure that they will trust, but we have to figure it out.
To me, that is what D. Hock said. You know, we had to figure out how 200 banks
and a heavily regulated industry that was a mess would trust each other enough
So, anyway, I think those are our challenges and perhaps more your
challenge than mine, although we have got our sleeves rolling up, you know, in
the trenches trying to figure it out. So, I think it is all of our challenge.
But at the heart of it is, there is no national standard right now.
Match rate dependency, some of the better match rates, I think, depend on
the social security number and I want to talk about an issue that we have had
recently arise out of that because social security number is frequently used in
public health in our health services research. We are heavily dependent on this
for what we do right now and we are doing a good job with the data, you know,
the probablistic linking and we are addressing some really — concerns that we
need to be addressing with it, but there is an issue that is hovering out
there, lurking, that is going to get us, we believe. The social security number
is really a proxy to a unique identifier in our mind.
Currently, because there is no unique identifier, what states have done and
regions like ours have done is to get very ingenious sort of — or creative in
how we can create a number that works effectively for us to do our job better,
to take care of the populations that we are serving. So, in order to link those
patients’ records with a reasonable degree, we need to use that field and the
social security number is the most discriminating variable and I think that was
discussed in a number of your — a couple of your presentations that it is the
most discriminating factor. That is where you are going to get the best match
The social security number is not necessarily a unique ID because we know
we have got people sharing social security numbers, especially those folks that
are coming across the border and they have one of their family members that
actually has a social security number. We are seeing quite a bit of that kind
of thing in our region with Texas having a heavy population and influx from
The social security number remains the most discriminating field, though,
which means it is a powerful linkage and we are dependent on it. So, how big is
the issue out there period? I asked the National Association of Data
Organizations to estimate the dependencies on social and they estimate that
there are approximately 30 hospital statewide discharge data systems on the
social right now in some form or fashion.
But, again, this is all retrospective data, not real time data feeds and we
believe that we need those for the RHIO and our public health information
networks. We also believe that you can use a lot of that infrastructure dually
and that there is not enough money out there to build a system over here that
will address public health and a system over here that will address our
regional information network.
As we are looking at our health information technology plan for Texas, we
are going to be looking at how whatever we do for Texas, we can jointly address
these concerns and what we build will work for both potentially. The
discussions of where they are in the DFW area, we believe that the master
patient index is going to be our biggest challenge and I believe others are
saying that as well. We believe that patient participation is a prerequisite to
success and that the patient must be engaged and excited about the benefits.
They need to be educated about the concerns involved and the integrity of the
program and feel confident in it.
We have considered it an opt in, opt out and I think that this has its own
challenges because then if you have got some that opt in and some that opt out,
what do you do with those that opted out? So, you are back to your linkages
that have all that error in them. Yet, clearly, we believe that citizens and
people will see the benefit once they opt in. If we build it right — I hate to
use the old trite expression, if we build it, they will come, but if we build
it right, if we build it the way we ought to build it, where you and I are
going to go through the system and use it effectively and be happy with what we
— our experience we have had, which I think is a huge challenge, having said
that, but I think if we build it right, people will begin to see the value and
that is our challenge for sure.
We believe they need to be involved in our we are building it in order to
build it so that it will be successful. The data model must evolve over time
and we believe that there will be a minimum data set established with some
demographics and those clinical items that are a must have. So, we are talking
incrementally here. Other data elements besides those fundamentals would be
determined by goals and objectives and, of course, whatever we do, we want to
watch what is happening nationally around these standards and the certification
process and what your group decides.
We don’t believe that algorithmic matching will work for clinical care. On
of our CIOs in the region said this. “If any organization or region uses
algorithms to link my medical records, I will request to see the screen to make
sure that is me on the screen.” Then you have really got HIPAA concerns
when patients start saying I want to check that. All we need is a few errors
and we lose trust immediately. So, I think that we can’t afford the errors. So,
any error is too much error.
Systems currently in place that use this method often have multiple strings
of records representing one patient and we have some examples of those. We have
hospitals that have spent millions to — because they have encounters that have
multiple records on one patient. So, they don’t even have the longitudinal
within a system or within a hospital. So, our hospitals have implemented these
things and I will tell you kind of an anecdotal funny story. We found out that
a 90 year old mother had been lying about her age for years, which we all
suspected. Now, she says she is 95 instead of 90.
We found it out when we admitted her to one of our hospitals and
implemented one of these very sophisticated systems and they said, well, Mrs.
Kirstie(?), were you born in 1914 or 1916 or 1918. She had three different
birthdays. So, they found it, but then they had all these strings of the
electronic record. So, extrapolate that nationally for state or regionally. An
incomplete medical record when assuming one is complete could be more dangerous
than assuming you know nothing and starting on a full history.
So, we think that there are some real challenges there. The time to
implement a national MPI with implementation of a National Patient Index is
going to take a lot of time to penetrate all the way through our system. We see
it when a hospital — even a hospital, not a hospital system introduces unique
identifier, a master patient index. It doesn’t permeate all of their clinical
systems. Maybe their lab system is in isolation.
So, they get in to having to create mechanisms to link and that is just one
small isolate of what we are going to face as we move forward nationally. So,
once again, I think, that Visa model and how they did it is something we ought
to look at because they did do it.
This is the big underlying thing that I talked about, this hovering that I
think we are going to have some real problems with if we don’t figure out how
to address this in the short term. Patients are refusing to provide their
socials. So, we actually looked into this recently and I am getting sort of the
hook here, so I am going to quickly just tell you that sort of the big thing we
looked at was the risk benefit here. Risk in the long run does the patient
There have been no violations of HIPAA in our area and, in fact, NADO has
told us there have been no public domain data programs that she is aware of
that have had a HIPAA violation around the management of the protected health
information networks. So, the risk is small. The benefit is huge and actually
sharing it. But it is that trust factor again and our patients are concerned
about this and how are we going to deal with it. And education we believe is
But we also need to tell them that something else is coming if we can
because they are nervous about using their social security number.
So, in summary, the nation, the public at large would — we believe we
would benefit from a national patient identifier. We don’t know exactly what
that might look like, if it surfaces, yet. We think trust is a factor that is
required for the success of it and strict adherence to HIPAA guidelines.
Everyone needs to watch everything they are doing with regards to privacy and
we, you know, follow those old ISO techniques of documenting everything you are
doing around the management of the data.
It will take years to effectively implement the NPI through the nation and
to eliminate that dependency and we should look at other industries as an
DR. WARREN: Thank you.
I think in the interest of time, what I would like to do is I know Jac
Davies is on the phone, is have Jac give her presentation and then we will open
it up for questions.
Thank you very much.
MS. DAVIES: My name is Jac Davies. I am with Inland Northwest Health
System, Spokane, Washington.
DR. WARREN: Yes. We need just a second to get your slides up, but go ahead
and introduce yourself.
MS. DAVIES: I appreciate very much the opportunity to speak with the
committee this morning for me and afternoon for you.
I am going to talk a little bit about what kind of an organization we are
because that really goes to the heart of how we are using a master patient
index and how it relates with the whole issue of RHIO because we have in some
ways a unique situation here in the Northwest and in some ways, I think, a
model situation that a lot of other parts of the country can learn from.
Have you got the slides up?
DR. WARREN: Yes. We are on your first slide.
MS. DAVIES: Okay. If you could switch to the second one where it says
So, I think that that little bit of background will be very helpful for you
in understanding the context that we are coming from. So, the master patient
index and how we are using it in our organization and then more about the
concept of an enterprise master patient index as part of the RHIO that we
participate in and then give you some final thoughts about how this, I think,
some of the decisions that you are trying to make.
Inland Northwest Health Services is somewhat of a unique organization. We
are a non-profit. We are owned the hospitals in the city of Spokane, which is
in eastern Washington, in practically Idaho. We provide services to residents
across the entire region and part of that is because of the nature of the
health care system here in Spokane. It really is a major medical referral area.
So, we draw patients from across, particularly eastern Washington, northern
Idaho, western Montana, eastern Oregon and also down from Canada.
What INHS does is work to improve clinical outcomes particularly through
assuring information access to all of the people who need to have that
information to provide clinical care. As part of that, we have become a
custodian of what is really a regional clinical data repository. I will talk
about that more in a moment. Because we have established this data repository,
we are able to maintain strict data structures and to really standardize that
data in a way that allows very accurate sharing and comparing of personal
We work as a shared service organization. So, the hospitals that are part
of our system and not just hospitals but also physician offices and clinics and
so forth have been able to create leverage by collaborating in a way that lets
them control costs. One of the things we have been able to with that is to
create — put in place advanced systems that increase patient safety.
A little bit more about what we are. Currently, we have about 34 hospitals,
mostly independent hospitals with over 2,500 beds that are participating in a
single hospital information system that we operate on their behalf. The
majority of those are small, rural, critical access hospitals, 25 beds or less.
We also have some very large hospitals, Sacred Heart in Canada, over 600 beds.
We have several 300 bed facilities. There is a couple of hundred bed facilities
and then the rest are all smaller.
Again, when I say that there are facilities, I mean, they are participating
in our network. We do not operate any of those facilities. Because we have this
integrated information system, we have been able to set up a lot of processes
for information exchange. There are a lot of physician offices in our region
that have electronic record systems and we have set up processes to do standard
HL7 messaging between our hospital information system and those EMRs.
But it is not just our hospital information system. We also have worked out
arrangements with a regional reference laboratory and a regional imaging
center, as well as a national laboratory, where they go ahead and they send
data through our system as well. So, any physician that needs access to either
inpatient data, to laboratory data and imaging data, they can go get that from
one place. If they have an EMR, they can get it via standard messaging. If they
don’t have an EMR, they can view the data via a virtual private network through
a variety of interfaces.
They can also, if they are going to the hospital, they can download the
data wirelessly onto their PDAs. So, they have pretty much done away with in
many of these hospitals with the paper chart that the physician carries around.
So, they are accessing the data, as I said, on their PDAs.
We also are working on implementing computerized physician order entry in a
number of the facilities. That will really complete the loop. The physicians
can both electronically and — can both view and enter data electronically.
Another piece of our system is a large telemedicine network. So, we have
also done quite a lot to integrate the concept where the telemedicine system
has some interesting projects going that way.
We should be looking at a map and that map is just to give you a sense of
where we are geographically located and the scale because the scale is quite
large. We are talking about a very large rural area, a lot of very small towns.
Spokane is the largest population center, as well as the largest health care
system east of Seattle and west of Minneapolis. So, that is why we have such a
large patient draw.
Most of the facilities we provide services to are in eastern Washington,
northern Idaho, that region, but we are also now starting to link up with
hospitals on the west side of Washington State, as well as into southern Idaho.
I have been talking about Inland Northwest Health Services and now I want
to talk a little bit more about the community governance process. INHS is, as I
said, owned by the hospital system here in Spokane and really exists primarily
to serve the hospitals and their customers, the physician offices that they
In parallel, here in Spokane, there was a group that formed in 1997 called
the Inland Northwest Community Health Information Project or INCHIP. That was a
group of physicians and other health care providers, including INHS, that came
together to talk about how they could collaborate on health information
technology projects. That group has become the guiding body, the governance
body for the community projects that have been undertaken.
Last year, that group made a decision to go ahead and take the next step in
their evolution and are becoming the Northwest Regional Health Information
Organization, the NwRHIO.
The INCHIP has really been filling the governance role. In some ways it is
an informal governance role, unlike some of the other RHIOs that are being
established around the country. The INCHIP has been serving as advisory and in
some cases decision-making body on community-wide standards and processes.
So, for example, on a decision-making standpoint they made the decision
many years ago that they were going to standardize — as the way to move data
electronically. On an advisory standpoint, they put together a short list of
electronic medical records that they would recommend to physician offices in
the community because they recognized that the shorter the list of EMRs, the
easier it was going to be to establish the interfaces between different
So, it is those kinds of activities. They have put together a
prioritization list for community-wide projects and a community — index, which
we will talk about more, as one of their high priorities. It is a voluntary
coalition. Members get together monthly. A lot of it is collegial discussion
between one physician or laboratory and another. What are you doing? What are
we doing? How can we do it better together?
There is a formal governance group and they really function as the guidance
body for the community. Now, it is possible that as we evolve toward a more
formal RHIO, that this governance board is going to be modified or a new board
that reflects more of a RHIO membership. But because the — northwest has got
INHS, because we have already got the technology infrastructure established for
a lot of information exchange. What we are really focused on with the RHIO is
more at a policy level for governance. So, again, we are a little bit different
that way than other parts of the country.
This is just a short list of the members of the northwest RHIO, the formal
members, which includes INHS. I mentioned Pathology Associates Medical Lab. It
is a large regional laboratory that is based here in Spokane. Inland Imaging is
a large imaging reference center also based here in Spokane.
The Community Health Association of Spokane is a federally funded safety
net provider, a number of clinics in the region and so on down the list to some
private clinic systems. The public health agencies here in Spokane and also in
Coeur D’Alene, Idaho with that having the whole sisters, they are right across
the border from us and many, many physician offices and clinics.
Now, you should be able to supply this title, INHS MPI. The master patient
index issue is really twofold. First, I am going to talk about how it works
inside the INHS system. We have a single hospital information system that we
are operating in all of our participating hospitals and that happens to be one
made by a vendor called Meditech. In all of those hospitals, there are approved
personnel, who can add new patients to the system. They use a fairly standard
algorithm-based query process.
So, they can go in if they have a patient who shows up in their hospitals,
they can check and see whether that patient exists in the system and it is not
just whether they exist in that hospital’s prior record, but it is whether they
exist in any of those 34 hospitals. So, that query process is something that
is, I think, fairly typical. It is looking at a combination of identifiers,
including social security. I heard Susan mention that that is becoming more and
more problematic and that is certainly the case for us as well.
If there is no match whatsoever, then as the hospital is allowed to enter a
new patient and a Meditech master patient is assigned — index is assigned, if
there is a match if it is an absolute exact match and there is no question that
it is an exact match, then the existing master patient index is returned to
that hospital and they put that into their medical record for that patient.
So, the Meditech master patient index is used by all the facilities on the
network. These facilities still have developed individual medical record number
and that is what they use for all their internal tracking. In fact, that is
really all they see. The system-wide master patient index is invisible to them.
But it is used to link records across the system.
As to what that means is if a patient shows up at the ER in Spokane and a
physician needs to find out where else they have been treated, they can look
back and they can find records from a year ago or two years ago, where the
patient was also treated at a hospital in Othello, which is 200 miles west of
us. They have access then to all of those prior hospital records. All that is
done based on the existence of an occupation index throughout the system.
Now, I mentioned that we have 34 hospitals currently on the system. Two of
those are just in the process of joining and our network has grown. We started
in 1994 with about six hospitals and we have been adding hospitals each year as
they have become aware of the model and are looking for a more cost effective
way to manage their health information.
So, it is fairly routine for us to add new facilities. When we do, we use a
batch process to compare our records to those in the hospital system to see if
there is any overlap. As I said because we are a regional referral center, then
that has been fairly common because there is a lot of movement between
hospitals and the system.
As we add more and more hospitals outside of our region, that is going to
become much less common. But that prematch is run on a batch basis and, again,
with the querying process, if the match is exact, if there is no question, then
they go ahead and link the existing medical record number to the existing
master patient index. If it is not exact, then the facility has to go through
an add process, just as I described before when they are adding a new patient.
It is not just hospitals that we map records to. I mentioned the Pathology
Associates Medical Laboratory. Over several years, we have gone through a
process of matching our master patient index, our records to their records. We
used a similar process to that one I just described for the new hospital.
OAML, Oncology Associates Medical Laboratory, partly covers the same region
we do, but they have more broad coverage. They actually provide laboratory
services across about a seven or eight state area. So, we don’t get a huge
amount of matching with them. It is more on the order of 40 or 50 percent where
we find that we have got the same patients that they do. But we do that
periodically to catch up and make sure that where it is possible to match the
patient, we can move the data based on that.
For another organization, we established a real time query process and that
has been a little bit more arduous to work out. So, that was for the imaging
center, where we set up a process where they can — a person at the imaging
center can actually query the system and see whether the patient exists. That
is built on the HL7 transactions for an eMPI query. So, that allows them real
time. If the patient is standing there and they are trying to get registered,
they find out if their patient already is — it is an operator-based decision.
Meditech doesn’t make the decision for them but it gives them enough
information to make some kind of a conclusion on whether it is a true match.
Just some matching issues, some things to be aware that we have learned in
matching between organizations because we are often matching between disparate
systems, as I just described. We do require, as I think Susan described very,
very well, a variety of data elements in order to match, for example, date of
birth, sex and social security number. Realistically, many organizations don’t
have all this information, especially laboratories. Laboratories are much more
likely to simply have some kind of a medical record number that they have got
from the ordering facility, whether it was a hospital or a physician office and
they may not even have a patient name.
Their customer is first the group that ordered the test and as long as they
have got that identification, they don’t need anything else or at least they
haven’t historically for laboratory testing purposes. But as we are moving into
this age of electronic data sharing, they are going to need that information.
So, it is going to become more and more of an issue on who has what data so
they can do the matching.
The other thing we have become aware of in matching is the issue of
duplicate records and the bigger your data sharing process gets, the more you
are going to be bringing in organizations that may or may not have a lot of
experience in managing their data and may or may not be creating a lot of
duplicate records. It is one thing to be working with group health
cooperatives, where they have got a very sophisticated ability to manage the
health information. It is another to be working with a ten doc clinic here that
may or may not have that level of sophistication.
So, you have to recognize that when you are sharing data and you are
starting to develop a multi-organizational system of sharing data that the
weaknesses of what can proliferate amongst the weaknesses across the system.
So, if there are problems in how data in one system is managed, if you are not
careful at the get-go, then that can proliferate throughout the system.
The next slide, which brings me to the question of the moment of the
enterprise master patient index in RHIOs and how that is going to function, how
it is functioning there now and what we indicated at least for our future.
There is no question that identification of the patient is the critical success
factor in a RHIO. The whole purpose of a RHIO is electronic record exchange and
if you cannot identify the patient, if you can’t make sure that you have got
the right person before you send that data off or before you, heaven forbid,
merge records if you are not sure who the person is, then you cannot run a
So, it is very, very important that the MPI issues be worked out up front
and then you make sure that you have got standardized processes for
identification in place. It is also very important to recognize, as I said
before, that one organization’s recordkeeping decisions and processes are going
to impact everybody else. So, you have to have agreement on those up front.
But where we are here in our region and I think that is fairly typical is
that every organization, whether it is a one physician office or it is a ten
hospital network has got some kind of a medical record number for tracking
their own patients. Then there are two options really at the community or the
regional level. We can try to get everybody to agree to use a single identifier
and just change their medical record number to whatever everybody has agreed to
or you can take the mapping approach and map the organizations, medical record
number to some kind of a single community identifier.
As I described, that is really the approach that we are taking here. So,
what we are looking at as part of the northwest RHIO is a joint purchase, some
kind of a commercial product and I understand you have heard from some of the
vendors about their products in the past. But that product would assign a
community MPI and then link that to their institutional medical record number.
The difference between that and what we are doing now is that we are doing
it pretty much in a case by case basis. So, INHS has got an application index.
If we want to link up with a laboratory, we work with the labs and we match up
and we realize — identify the common patients and assign a common number. But
we recognize that as this thing grows, as the northwest RHIO grows, that we are
going to run into real scalability issues.
We can’t realistically on a case by case basis do that for every clinic
that has got a different EMR system or do that for every national laboratory
that wants to run data through our system and so forth. We need a more
formalized approach and a more efficient approach to assigning an MPI. That is
why we are looking at these commercial products.
Interestingly, as we have talked to the vendors, the RHIOs are a new issue
for them. I mean, their whole experience to date has been single facilities, a
hospital or other organizations or wholly owned networks. So, if there is a
hospital organization that might have ten facilities across the country and
they want to run a common MPI, that is a model that the vendors are used to
because they know how to — they ask how many medical records do you have, how
many patients do you have and they can figure out how much to charge.
But the RHIO model is very, very different because you have got multiple
organizations in many cases treating the same patient. So, you have got a
patient who shows up at the imaging center and also at the lab and also in the
primary care provider’s office and in two specialists and at two hospitals. Can
you tell us for each time that patient gets — based on the number of patients
in the region? It is a major question and we have interesting conversations
with the vendors about how they want to handle this.
We don’t have an answer yet. The other piece, of course, is scalability.
RHIOs are a moving target. From day to day it seems like the concept is
changing. Are we talking of communities? Are we talking a region, a state,
multi-states? So, how do you define some kind of enterprise master patient
index process when your final scale is completely unknown. How do you assure
scalability when you might be working with five million records or twenty
So, those are some of the things we have encountered as we have begun to
look into and decide how this region is going to handle the enterprise master
patient index. This is a few summary comments before we open up for questions.
I understand that one of the things that you are revisiting is this issue of a
national patient identifier and would a unique patient identifier simplify
information exchange. There is no question. It would be wonderful. Even though
we are a community that already has done a lot with data sharing, when our
community put in a RHIO response to the request for information that was out a
little bit over a year ago from our kit and we strongly recommended that a
national patient identifier would be a terrific idea for health care.
On the other hand, is a unique patient identifier absolutely necessary for
a RHIO to do data exchange and we also agree the answer is no. We are doing it
now. It is possible to do without a unique patient identifier. It is harder. It
may be more problematic, although the vendors will tell you that the matching
algorithms are good enough where it is not a — it is not anymore problematic
than having unique identifiers, but there are certainly a lot more policy and
— issues to work out without that unique identifier.
In terms of using a master patient index in RHIOs, there are, as I said, a
lot of things you have got to decide on up front. You have to agree on how you
are going to identify. If you are going with an algorithm-based approach, you
have to agree on what that is, what elements are you going to use, when are you
going to identify a patient in the health care process, what are you going to
be using for matching and how rigorous is your matching criteria going to be
and what are you going to do when they don’t match. How are you going to manage
duplicates and how are you going to deal with duplicates that have proliferated
throughout the system? And is there going to be — I didn’t put it on the
slides — what do you do with unmerging if you have realized there was error in
the matching process and so on?
We do have to have some kind of tools for querying and for assigning an MPI
across all of these systems and most important you have to have trust. Susan
talked quite a bit about the trust that the committee, the patients have to
have, but there is also as you get into developing a health information
exchange between organizations that are completely unaffiliated with each
other, then you have to have a great deal of trust in each other and that they
are not going to mess up your data and cause problems for you and your
Which brings me to my last slide, which is a little personal experience I
have recently had with matching gone bad, not in the health care fortunately,
just a much smaller problem with my credit history, but I found it fascinating
because I had just been working through this whole issue of matching patients
and I found out accidentally that my credit records have been merged with
someone else’s by the credit reporting agencies.
As I studied it, I realized that the credit industry must have matched my
record with this other person’s, who happened to have been my father-in-law on
very, very few data elements. They must have matched only on last names, which
was the same spelling, a similar sounding first name — my name is Jac, which
throws people, but it is — my father-in-law is the same, although he spells it
differently. The address, at one point we lived in the same house when my
husband and I were first married and we lived with his parents for a few
That is what we had in common. What we didn’t have in common was gender,
social security number and most importantly from my perspective mortality
status because my father-in-law, unfortunately, is dead. The reason I found out
about the whole issue was that I was denied a credit card because they said I
So, I was fascinated by the fact that this industry, at least, the credit
industry doesn’t appear to have taken the issue of matching and identification
very seriously and doesn’t have any problem merging records, even when there is
very, very little evidence that one person is the same as another. It gave me
much more appreciation for the health care industry and its efforts to do it
right, also recognizing that if the health care record is inappropriately
merged, the consequences can be much, much more serious.
So, as I said, I commend your committee and your efforts to make sure that
health care is doing it right and with that, I just would like to open it up
for any questions.
DR. WARREN: I am glad the committee enjoyed the story. When Jac and I were
talking on the phone getting ready for testimony, she shared this with me and I
said you have got to put that on the last slide because I thought it really
grounded us with the dialogue that we were going to have.
So, with that, Susan, if we could have you come back up to one of the
DR. STEINDEL: Judy, while Susan is coming up, I would like to comment. I
actually related to her comment about her — was it your mother-in-law lying?
Because my mother did it until she was in her seventies and we found out about
DR. WARREN: I was going to say probably we all have mothers that have done
that because I was telling Maria my mother has also lied about her age, but she
always tell the truth about the year she was born. So, we have not gotten into
these troubles but we have never really known how old she was.
Okay. First question, Jeff?
MR. BLAIR: Thank you, Jac. Thank you, Susan. Very grateful for your coming
and testifying on your to some degree pioneering experience with trying to pull
together some form of an emerging RHIO and trying to grapple with the idea of
matching patients to their records. Clearly, it is one where there is not a lot
of good paths and you had to find your way to what works.
We have had a number of other testifiers. Most of the others have been
health information exchanges and most have, in fact, indicated they have used a
probablistic approach and that, you know, the key identifiers were the name,
the social security number and the date of birth. So, all of those things are
similar and they also indicated that the social security number was the most
reliable, the key identifier.
The question that I have a little bit is your pathway and the things, the
problems, impediments that you have encountered as you have come to the
conclusions that you have come to, since you have chosen the probablistic
approach, did you encounter — well, let me just zero in on two specific
questions. I will just do that and then let other people ask questions and then
if there is time, I will come back on some more.
No. 1, with the probablistic approach you have to strike a balance and from
other testifiers, they have said that they could have a higher percentage of
matches if they would tolerate false positives. But if they do, they run legal
risks, patient safety risks. The other testifiers have indicated that they have
been gravitating towards coming up with algorithms that will be zero false
matches, even though it means that the percentage of matches is higher and the
work load is higher.
So, I would like to know if you have developed policies that are similar.
The second question — there are two questions. That is one. The second
question is even though this is only matching patients to records, when you
have gone around to health care providers and health plans and clinics, have
some of them said I am not going to play because of my concern about your
having some degree of access to the records that I have and I consider them
either an asset or a competitive advantage or that there is a privacy issue and
if you have, what have you said or done to get them to cooperate? Those are the
two questions. If both of you could address those.
MS. DAVIES: Susan, why don’t you go first since you are there in the room.
DR. MC BRIDE: Okay. I think probably that second question is a little bit
more for you, Jac, since you are linking the labs and the pharmacies and the
physicians and we have begun to talk amongst each other, but we haven’t
actually done that piece yet. Ours is primarily with our hospital sector that
we are working with right now. I think one of the things you have to — people
talk about the use case, I think, with previous testimony and why are you
linking? What is the purpose of the probablistic linking? Of course, in Jac’s
case, it is definitely to deliver clinical care, which is the direction we are
headed in in the future.
What we are doing with it now, though, is to address patient safety and
quality to look at health services research questions and they are very
specific isolated questions on the health research side. So, we work with the
researchers to decide the sensitivity, specificity issue and, you know, whether
or not to manipulate in that fashion. So, it is really sort of a different use
case and I think the probablistic linking for those purposes is adequate. It is
good enough, but on the other hand as Jac talked about are issues with clinical
care and this is what our CIOs, our chief information officers in the region
have said, that is not going to be sufficient when we start moving into the
clinical arena, we don’t think.
Some of those very issues that Jac described, we have a 15 hospital system.
We have a 13 hospital system. We have HCA and Tenant(?) in our area. So, I
think that as we begin to look at how we are going to address this regionally,
we are hearing our CIOs tell us we have to move forward the master patient
index of some sort. We need to figure these problems out and that is going to
be our first step.
We are not going to link — use other methods. We want to figure this out
first. So, right now, the trust piece that Jac spoke to as far as the
government model and that is why we really were enamored with the Visa story
because he established that trust component of partners that would have them
all be willing to share data, which I think was Mr. Blair’s second question. We
think that it is in the governance structure, which Jac sounds like she has got
a beautiful governance structure out there that probably has addressed a lot of
what — and we are still going to have those players that may say exactly what
Mr. Blair said. So, I think we are going to have to do it as a committed
What we recognize — there is a lot of momentum in our region, as it
appears there is in Jac’s, where providers are saying now we have got to work
together and hospitals have been doing it for some time. But the physician
community is equally as committed now and our politicians in the area are
interested, our county commissioners, our uninsured rights. That is the pain we
are getting hit with. We have 24.6 percent of our state that is uninsured right
now. How are we going to deal with that?
How are we going to manage the health of those populations and we haven’t
seen the Rita/Katrina effect that Texas is going to get hit with the uninsured
that came in from that episode. So, those are — I think that is how I would
answer it. I will hush now and let Jac respond.
MS. DAVIES: Okay. Thank you, Susan.
On your first question, Jeff, the issue of is a probablistic approach good
enough, definitely we are being very conservative about when we declare our max
and we are going to make a decision to merge records. At one discussion we had
an extensive discussion about that. The group agreed that duplicates, when you
are talking about a personal health record, duplicates are less harmful than a
bad merge. The reason for that, particularly from a RHIO perspective is that if
you have got John Smith identified under — at three different facilities, a
different MPI associated with those, so you have gotten duplicates, when
somebody does a query to see those medical, they may get three John Smiths, who
are all the same person, but from a health care perspective, that doesn’t
matter so much because they have got all the records.
They may have to sort through them a little more than they would if they
were merged, but at least they are all going to be there. On the other hand, if
the records are merged in a bad way, then that could very much affect health
care. So, we have been conservative about the decisions to identify a person
and to merge the records. We feel it is not from a health information exchange
standpoint, duplicates are less harmful and that can be dealt with more easily
than a bad merge.
On your second question, has anybody —
MS. BLAIR: One piece on that. One first question was really related to will
you tolerate or accept a false positive, two different records that appear to
be the same person, but are really not?
MS. DAVIES: Well, no. I think we are being conservative on that as well.
So, that is why I said that we tend to not make a decision that it is the same
person, unless there is very, very strong evidence that it is.
MR. BLAIR: Thank you.
MS. DAVIES: Okay. Then has anyone said no? One of the great things about
this region is that they have been working at this long enough where for the
most part both the large organization, the hospitals, the labs and so on and
certainly those physicians are well past the point of regarding data as an
asset. I know that is not the case in all communities, but one of the great
things about the INCHIP, that governance group I mentioned, is I heard from a
physician, who was a founder, that they made a decision from get-go that they
needed to treat information as a public good and it needed to be treated in a
way that would serve the best interests of the patient, not as a way for each
organization to achieve some kind of dominance over the other ones.
So, just culturally, it is a good place to start and then sort of how have
they, even those who don’t have electronic medical record systems and so on —
or they are surrounded by those who do and who are touting the successes and
the way most of them are treating these electronic transactions is as an
extension of the paper exchange that goes on all the time and, again,
remembering, of course, that health information exchange happens everyday. It
just happens on paper.
So, philosophically, when you send the file electronically versus having a
courier carry it over to the office, you are doing the same thing. So, I think
that is the attitude that most of our providers have taken so they don’t see
this as a threat or anything that is going to be different than their current
DR. WARREN: Harry, you had a question?
MR. REYNOLDS: Thanks to both of you, outstanding job.
The question I have is both of you alluded to a standard minimum data set
that might be used in whichever method that you select. The other thing is both
of you mentioned the social security number as the identity theft laws roar
across the country right now. How are you dealing with that? I mean, I think,
Susan you alluded to it that some people won’t give it up and more and more
state laws are going to penetrate how you actually do business and whether you
can or can’t even have it.
If both of you could talk about the minimum data set and then the social
security number, I would appreciate it.
DR. MC BRIDE: This has been a big challenge and I think, you know, some of
it is educating both the legislators, as well as the general public about our
independencies right now and the fact that we are diligent around protected
health information and that is what HIPAA was all about. HIPAA was about trying
to get safe transactions as private health information and if you can convey
that — and they know about HIPAA. You know, they experience it enough now
after our anniversary, where — the public know about that. So, that so far —
we even have one of our major systems that put together an educational script
that they are going to share with the rest of the hospitals around how do you
educate the public about these issues.
Likewise, I think, you know, the consumer groups that are beginning to
express concerns, but I think we equally need to say we are dependent on it now
and we are trying to solve this problem because I don’t think it is our long
term solution for us to be dependent on the social security number, but it is
working for us right now and if we didn’t have it, we could not do as effective
surveillance. We couldn’t do as effective work with our public health
departments, the health services research activity that we are doing and the
linkages that we are doing. We couldn’t do it, not nearly as effectively.
So, I think those are our challenges if we have to need to move away from
or will be forced to move away from it.
MS. DAVIES: I think that the impact of having increased concern about the
social security number is just less and less reliable matching and increased
reliance on other data elements, address being one possibility, that, you know,
the — going through the name matching process as much as possible. So, the net
effect is going to be less reliable matching and probably a greater number of
duplicates formed in the system.
I think that we as a health care industry can talk all we want about all
that we are doing to protect our records and anything we say is defeated by the
article — the individual incidents, like the health records that were in
somebody’s car and the computer was stolen in Oregon recently or the University
of Washington, having somebody hack into their medical record system.
Those get far more press and far more attention from the public than
anything that we say. So, if we can, as the vendors say, rely more on a complex
— a range of data element and not just the social security number, we are
probably better off. But, frankly, I don’t know and don’t have enough
experience to know how valid the claims are that we can rely on a dozen
different data elements and get just as good a matching.
MR. REYNOLDS: So, do you think a minimum data set is a dozen or do you
think it is three or five or six or —
DR. MC BRIDE: That is one of the things we are looking at in the State of
Texas right now with our new health information technology advisory committee
is what do we think the minimum data set should be. I think one of your
discussions talked about hierarchy and at the clinical level that Jac is
talking about you need tremendous detail, but then at the regional level does
there need to be less detail for you to — and that whole idea is one that we
are definitely looking at and, you know, it is always better to have multiple
people working on what the issue — and I think, you know, we are sort of
waiting on the national standard and we are going to look at it as the
recommendations come down on what the minimum data set — we have some ideas
that — and we have clinicians that have said what they believe needs to be the
minimum data set.
Clinicians will tell you, you know, the more information we can have the
better, but then digesting that information is challenging. So, I think
electronic digesting of the information is actually very — really different
than if you are flipping through a paper-based record and those will be our
next challenges, once we get all this.
MS. DAVIES: Well, as I just think about that, I don’t know what the number
is, but I have a public health background and my reaction to that is it is like
a disease investigation or making a decision about a public health
intervention. You are balancing the risks and benefits. So, there needs to be
enough guidance as organizations are trying to make decisions on a master
patient index or a matching process. There needs to be enough guidance to know
that three elements are too risky and twelve elements is so conservative, it is
going to take you two hours to do a match or whatever. You need to — your
benefits of that are that you have reduced your false positives or your false
negatives down to x percent.
So, that kind of guidance on what are the risks of a certain matching
algorithm and what are the benefits of it so that organizations can make those
decisions would be extremely helpful.
DR. MC BRIDE: I may have misunderstood your question, Mr. Reynolds. Were
you actually talking about a minimum data set for matching or minimum data set
for sharing of information? Which were you speaking to?
MR. REYNOLDS: The matching.
DR. MC BRIDE: The matching. Oh, yes. Okay. Well, we have settled on the
characteristics that you saw, you know, the name, the address, but depending on
what the issue is and what you are matching and how long across your matching
— you know, people move around and so there are challenges with even the
minimum data set and you saw what our minimum is, right now. I think as the
issues such as, okay, now you don’t have social security number, you are going
to have to — as Jac said, you are going to have to extend that data set
because that is what is getting us the most discrimination right now. So, if we
were to eliminate that or not have it or we begin to get more 99999s in our
data, we are going to have to depend on other methods for linking and more
MR. REYNOLDS: Thank you very much. Thanks to both of you.
DR. WARREN: Simon.
DR. COHN: This is just sort of an odd question that I am sort of curious.
This one is going to maybe be a little too far beyond but, obviously, I think
we are all talking about this issue of a data set as opposed to a single
element and I think can think to over the years hearing stories of, in fact,
social security number, certainly, alone isn’t all that good either.
Obviously, with the issues relating to people using social security numbers
will be confirmed with this other issue. You know, it is becoming obviously
increasingly common, though it is not universal, that people are paying with
credit cards for services related to health care. If you are D. Hocking(?)
conversation and all that, is there something to be investigated around
actually using credit card numbers as part of matching algorithms? I mean, is
there a — I am just trying to think of the terrible downside to that and I
know it isn’t as — I mean, people don’t necessarily hold a credit card for 30,
40 years or whatever, but, of course, as one of a number of items, have you
thought about that, looked at that? Is that a — is that so weird as to you
won’t even mention it when you go back to Texas or —
DR. MC BRIDE: Well, we do have people paying with credit cards and I think
we are going to see more and more of that because of the different health plans
that we have got employers dealing with their StopGap and we do have absolutely
they are putting them on credit cards. What I guess I see with the D. Hock and
Visa story is that there is a model there. There is a model of how they
establish trust, electronic exchange of data because that is basically — they
started out with this world view of we are the banking industry. We are a bank.
And what he realized is, no, we are not a bank. We are moving data around.
So, I think we need to use those types of scenarios, their story, and see
what fits and what doesn’t. But the unique ID that is on that credit card
number, I think, is what is a very powerful component of that story and then
how did they get people to trust enough to deposit that and then the security
and privacy around it all, the exchange of that information or the mainly —
and this is very early pursuit of looking at that. I mean, within the last week
we started kind of looking — investigating this and we have been thinking
about it for some time, but hadn’t actually talked to the gentleman until
MS. DAVIES: Well, I have to say my recent personal experience with the
credit industry doesn’t make me a little excited about that process, but I
think you are right, that we are going to have to be more creative about other
data elements that could realistically be used in a matching algorithm and I
see no reason why credit card numbers could not. I think you might run into
some of the same issues about public sensitivities that you are running into
over social security numbers, wanting to know why do you need my credit card
number or the concern about misuse of that information is likely to bubble up
as well. But it certainly is something that is worth investigating.
DR. WARREN: We are running close to time. So, I have two more questions.
Stan and then Robert.
DR. HUFF: So, one of the things that occurs is if you speculate about the
possibility of making unique identifiers for purposes of identifying people
connecting records, all of the things that we have talked about, one of the
issues is obviously the cost of producing that number. One of the things that
would be interesting, do you have any idea how you could or if you could put a
value on having that number in terms of the process of the system, decreased
waiting times for patients, the fact that you don’t have to do the matching or
at least in a big percentage of the cases you don’t have to, the fact that you
may have to have backup situations, but if people bring their card or brought
their number, how much it would expedite their care and the accuracy of their
That would in some sense be an offset to the cost of creating that number.
Any thoughts — would there be a way that you could put some monetary value on
having such a number available?
DR. MC BRIDE: Well, I think — and, Jac, you may be able to speak to sort
of the before and after picture of your entity, although it sounds like you
have some inefficiencies in the probablistic linking that a unique number would
help create efficiencies around what even you are doing in the northwest. But I
think one of the interesting things that Mr. Hock said, they have been looking
at this and so they really — they have been working with some organizations
and a physician group and they have done some cost benefit analysis and what
his comment was that the savings were potentially huge. So, we are going to be
exploring that. What would that look like? Where would it shave and has anybody
done any cost benefit analysis around that unique ID and I think quite frankly
in the DFW area, we are very early in that stage of looking at that, but you
can only imagine the inefficiencies built in how a patient — or you or your
family has gone through a health care system recently and how many times have
you given your health history recently. Even the workforce time that it takes
to do that, if you think in terms of man hours that we are losing in the health
care system just from answering your health history, you know, that, compounded
by millions of people, you could only fathom what the savings might be.
But we have got to do it well, too. Otherwise, we are going to create
inefficiencies that are going to have things happen that we don’t want to
MS. DAVIES: I think that if you are looking at trying to cost out the
difference between having a national patient identifier and not having to rely
instead on matching. You need to be able to tease out what costs and what
savings are specifically associated with the identification process.
We have not done that. We certainly have a lot of information on how much
it costs us to do a matching batch match against the new hospital, the Joy
Saar(?) Network, or to establish the query process. You know, so we have that
kind of information and I guess you would make the assumption is that for the
most part all of those activities would go away if you had a national patient
identifier to be replaced by some much simplified — someone would give you one
number and you would run that against your database and maybe a little bit of
backup information just to verify.
We have not done it. As I have said, it certainly seems possible and it may
be worthwhile to support the argument for a national patient identifier. I have
to say my personal feeling is that the sensitivity on that issue is so high
that even if you could demonstrate millions or more savings across the health
system by being able to do away with the matching process, that that wouldn’t
be enough to make it worthwhile for the public.
MR. REYNOLDS: I had a second question, a comment there.
You may be gauging the public correctly, but do you — I guess, is there
actual fact behind that. Is there a rational reason why having a national
identifier actually makes me less private and less secure?
MS. DAVIES: No, but that is speaking as somebody who is reasonably
knowledgeable about the health system and about how information technology
works. As I said earlier, I think that there is a great deal of emotion and
that you get a — the public hears a lot more and responds a lot more to the
press articles about when bad things happen, when there is a hacker or when
there are records that are stolen and so forth than they do to all the
assurances that we can make.
DR. HUFF: I agree. It is a question of perception, but it would seem, too,
that if there is really no basis, then you should be able to overcome that
hesitancy. My question is is there a real risk there or is it just a perceived
MS. DAVIES: I do not believe there is a real risk. I do not believe that
there is any greater risk of exposure for a person’s health information if they
had a single identifier than if they don’t. I don’t know how you convince the
public of that.
DR. HUFF: Second question. If you were to make a unique national identifier
for patients, what would be the ideal characteristics of that identifier?
MS. DAVIES: Tell me what you mean by that.
DR. HUFF: What would be the characteristics that would allow you to get
one? How would the initial assignment of the number happen? Should it be a
nonsense identifier or should it imbed some kind of information in a number?
Should it have a check digit?
MS. DAVIES: I am sorry. I really don’t know enough about the options, I
think, to be able to answer that in a way that is going to be helpful to you.
DR. MC BRIDE: I think that whole area is, you know, really mathematically
based. I have worked with enough programmers to know that alpha numerics and
the number of fields and how many times you will have to, you know, filter
through the data and all of that, there is a real science around that from a
data processing standpoint. I would bet the credit card industry — you know,
some of it has to do with a volume of people you are going to be putting
through it and the credit card industry has gone worldwide in their numeric
values and they are frequently alpha numeric. I guess what I envisioned was an
alpha numeric that would have quite a few digits associated with it, how it is
assigned and the whole process that takes place.
I hadn’t really thought through that.
MS. DAVIES: One comment, though, that has not yet come up is the whole
issue of biometrics and I know that a very, very primitive level, I heard a
story the other day about — actually it is here in town, Gonzaga University is
experimenting with a system where students use a thumbprint to get access to
food services and so on. It may be that a biometric approach would be more —
they would probably be more comfortable with it because it is not something
that can be stolen or imitated so readily and the technology may be getting to
a point where it is financially realistic.
So, just a thought about an approach here would be to not rule that out.
MR. REYNOLDS: Okay. Thank you to both of you, excellent, excellent job.
We are going to take — let’s get back at 3:20. That is about a 12 minute
break so we can continue because we have got two more presenters and we want to
make sure that we stay on time.
So, thank you very much.
DR. WARREN: The next presenter is David Espey, who is going to talk to us
about some of the issues the Indian Health Service has about data linkages.
DR. ESPEY: Thanks for the opportunity. We listened to the last 20 minutes
or so of the previous presenters. I focused on some issues that we think might
be more relevant to this discussion.
Most of the linkage activities that we do are for the purpose of data for
the improvement for epidemiologic purposes. So, with that in mind, we will just
go ahead and proceed. Both Melissa and I are Indians from the CDC to the Indian
Health Service, from the Cancer Division of CDC.
The two main linkage activities that we are involved in are between the
Indian Health Patient Registration Data and State Death Records and central
cancer registries across the United States. Those are records in both major
systems of cancer registries, one supported by the National Cancer Institute
called the SEER Registries that some of you may be familiar with and the other
one is the CDC supported system of cancer registries called the National System
of Cancer Registries.
We will focus on the — at least for now on the death record linkages. This
is very — and there are really two steps and we link records from state vital
statistics or cancer registries with the Indian Health Service Patient
Registration Database. That database includes individuals who have had some
sort of services provided by the Indian Health Service within the time frame
starting in the mid-1980s when various service units in the Indian Health
Service began using electronic patient medical records.
Is there anyone from around the mid-eighties, who has served within the IHS
or paid by IHS contract — is in the patient registration database and it is
approximately 2.4 million records. There is a lot of duplication. We
unduplicated only at the level — if someone has a complete match across
security, first name, last name, date of birth and gender. Then they will be
eliminated. Otherwise if there is any discrepancy in any of those fields, they
are maintained in our registration database just because we assume those errors
could be duplicated elsewhere.
Then the purpose of our linkages are to identify records and these
databases, either vital stats or cancer registries, who have been misidentified
or misclassified as non-native. Then the final sort of use — for us to use
these improved data report — mortality patterns and cancer burden of American
Indians and Alaska Natives.
— watching the slide show that we sent?
MS. FRIEDMAN: Yes. If you could please tell me when you are ready for the
DR. ESPEY: The fourth slide is linkage process. Basically, we went through
a procedure where we drafted a proposal and had a lot of interaction with the
states and agencies representing state vital stats registry, state cancer
We had research determinations both at CDC and the Indian Health Service
with the recommendation that this is really a data — improvement — not a
research activity. We elaborated plans for data management, the linkage
algorithms and an analysis plan.
New slide, data management. With each state and each registry, some
registries are run by the states and some registries are run by non-state
entities, like a university or a private contract, by a contractor. We had
memorandums of agreement, memoranda of agreement and data use agreements to
allow us to exchange data with the state and in most instances, the data for
the linkages were sent from the state to us by FedEx in an encrypted format to
our office in Albuquerque.
We then — the linkages and then sent the match results, which we call
Match File 3 and I will show you a graphic of that in a moment, which contained
both the Indian Health Service, the state’s record of the match pairs that we
felt were indeed matches. So, they could make the determination on their own if
they wished to review them to see that it was indeed the same individual and
then from that create analysis files.
This one is entitled “LinkPlus.” Basically, we use a probablistic
algorithm and we use a public use software that was developed at CDC called
LinkPlus, which is available on the Internet at the web site at the bottom of
the page. I don’t know how much of the detail that — I am sure you are
familiar with probablistic linkages and we use a system of blocking variables
to increase efficiency, whereby only records with matching key variables,
identifying variables are compared and it greatly speeds up the matching
The next slide, it is called “Matching Variables.” So, these are
the variables that we use for both the death record linkages and the cancer
registry linkages, social security number, date of birth, last and first name,
date of death, middle name, which is usually supplied as an initial and gender.
An example here using Melissa, my colleague Melissa, as the example. The
first pair — the fourth and fifth columns are the date of birth and social
security number. You can see that there is just a slight discrepancy in the
first name, but otherwise it is a perfect match. The program, the algorithm
generates a score for potential matches and she would clearly be what we would
consider a perfect or near perfect match. Then there is a whole other group of
potential matches called clerical reviews that are sort of the gray areas,
which require an individual review. What we do for clerical reviews is we have
two independent reviews of the group of these clerical reviews and then we
adjudicate them as to the discrepancies between the individual reviewers.
So, for instance, in that second — if somebody felt it was a match and
someone else — and the second reviewer felt that it wasn’t a match, they would
actually have to sit down and discuss it and maybe look for additional sources
of information from maybe the social security index web site or something like
that to make a decision.
This is just a screen capture of LinkPlus, which is a CDC public use
software and it is divided into sections to determine the blocking variables,
the matching variables and putting in the values for missing — missing values
for a given variable.
The next slide, “Data Flow,” this really is just in summary,
either the registry or the vital stats office and we link it — we generate two
files. One is what we call Match File 1, which is a perfect or near perfect
matches. Match File 2 are the clerical reviews, which get, again, adjudicated
independently by two reviewers and then any discrepancies between the two
reviewers are further discussed and oftentimes a third person will make a
decision and we tend to err on the conservative side. If we can’t feel
comfortable — and there is always a subjective element to this part of the
If we don’t feel comfortable that a person is a match, we don’t call them a
match, even though there is a pretty good chance they are a match. Then those
two groups of records are combined into a Match File 3, which is sent to the
registry of the vital stats office. We encourage the state officials to review
the records. Some do and some don’t and then after they do that, to delete the
Indian Health Service records that we send back to them.
The next slide, these are just the regional breakdown that we use. There
aren’t that many Native Americans and Alaska Natives and to have reasonably
stable estimates, we grouped fairly broad — we grouped the states in fairly
broad regions to have — for stability of estimates.
The next slide, these are just the results from — and this is the cancer
registry and these bars, you can see that the green part of the bar, they are
individual registries in the states. The green section are those that were
identified as Native Americans prior to the linkage and the red sections of the
bar are those that were added as a consequence of the linkage.
Again, our database is defined by the individuals being Native Americans,
based on their eligibility for IHS services, a tribal code and there is an
additional field called quantum, which is the degree of native ancestry. So,
between those three fields, the records and the IHS patient registration
database represent Native Americans.
The next slide is a very similar graph or bar chart for vital stats linkage
results that the discrepancy results aren’t as impressive as they are for
cancer registries, but they is still a substantial amount of racial — in vital
This parenthetically has been confirmed by linkages between the census data
and the National Center for Health Statistics, National Death Index where
health is self-identified in terms of their race, compared to the race as
identified by — at best, there was a large discrepancy between the two in the
order to 30 to 40 percent for Native Americans. So, in other words, a person
who is self-identified, said I am a Native American, when they died and the
information was gathered by the funeral home either by asking the question or
assuming based on the appearance of the person who was deceased made a judgment
and there was up to 30 to 40 percent error rate between the two ways of
collecting race information.
There are other linkage activities with IHS. We didn’t have a lot of time
to gather information about this, but very quickly, one is a routine or
quarterly linkage with the social security administration and that is to verify
the accuracy of social security numbers and IHS. The second one is with CMS and
that is to — I believe it is used primarily by CMS to track service provided
Native Americans and this is one of the easiest ways for them to correctly
identify those individuals as to link through the Indian Health Service. Then
there is an annual linkage with census and I think the census also uses the
data in relation to its being a race-based — essentially a race-based
database, but I don’t know that much about the census linkage.
So, that is sort of very brief overview of our linkage activities and we
will be happy to — Melissa and I will be happy to answer any questions that
the committee has.
DR. WARREN: Since David is dialing in, he is requested that he has another
meeting. So, could we ask questions now about David’s so that he can then
MR. BLAIR: David, thank you for testifying to us.
Quick questions and then — first of all, does the patient identifier that
you have for the Indian Health Service cover all tribes, Pueblos, the U.S. and
its territories or is it just southwest?
DR. ESPEY: It is all across the U.S. The major concentration is Native
Americans and Alaska Natives in the southwest, but much, much less east,
Oklahoma. But we don’t use — there isn’t an IHS-wide patient identifier. The
IHS is divided into administrative areas that you have an identifier.
MR. BLAIR: And they are different in different areas?
DR. ESPEY: It is different in different areas, right.
MR. BLAIR: Is it different by Pueblo or tribes?
DR. ESPEY: By area, administrative area.
MR. BLAIR: What do you do when Native Americans, who qualify as being
qualified under Indian Health Service, receive health care outside of the
system in terms of patient identification, both going in and out? The reason I
am saying in and out is you may have inter-marriage, where some folks may be
living in the city and then going back for some care on the reservation and you
may have other situations, where it is vice versa? What kind of patient
identification problems and matching and correlating have you had when people
go in and out of the system?
DR. ESPEY: So, if a person is treated outside the system using IHS contract
health funds, is that the question or — there are a number of people who have
— who are eligible for IHS services, who have insurance, their spouse, their
employment, who rarely interface with the Indian Health Service.
I am not sure I understood the question.
MR. BLAIR: Okay. Maybe I will be more specific. Let’s say you have somebody
that has been receiving health services on the reservation and then they head
into Albuquerque for some specialized care, in situations like that, do you
have difficulty — what kinds of difficulty, if any, do you have correlating
the records, the identity, back and forth between people receiving care with
inside IHS and outside?
DR. ESPEY: Well, usually it is in the context of using contract health
services that a person will — is referred to specialty care with the
understanding that that will be funded by the Indian Health Service. But there
is not a unique identifier that is used. I mean, their name, social security,
address and so forth — but IHS, i.e., that area specific is not used, at least
— I mean, there may be some providers or groups that collect but to my
knowledge it is not used as routinely as a — to manage the — you know, to
track the patient.
MR. BLAIR: It is really not a problem?
DR. ESPEY: No. What does — if a Sioux from the Northern Plains is in New
Mexico and they are not — the administrative area, which would be either
Navajo or Albuquerque area, they can receive IHS services at those facilities
but they are not eligible for contract health services. So, that person if they
needed specialty care not provided by the Indian Health Service, they would
have to return to their area. It would be your Aberdeen area or Billings to get
those services or they would be considered indigent and receive them, too, you
know, that mechanism.
The identifiers that are used in IHS have been problematic because there is
a lot of migration and a lot of duplication so a person may be assigned an ID
number in Albuquerque area and receive services also in Navajo area. When I say
area, I am referring to these administrative entities.
So, they may receive two different ID numbers and our patient registration
base, they will be in there two times unless all of the information was
recorded correctly, name, social security number, date of birth.
DR. WARREN: Okay. Thank you, David.
Any other questions for David?
MR. BLAIR: I just have one and this is — maybe if it is an example. Does
the population that you serve, Native Americans, have a very high percentage of
names that are identical? Because there are certain racial and ethnic groups
where the names are the same. There is going to be a lot of Rodriguezes and
Martinez in our area.
So, anyway, I am wondering if you are running into that and if so, do you
wind up with an algorithm that has been especially helpful in dealing with that
DR. ESPEY: With frequent names, frequent —
MR. BLAIR: Yes.
DR. ESPEY: Well, in the probablistic algorithm, there is a frequency
analysis that if a person has an uncommon name, then a linkage on the name will
get a higher score than a linkage or a match on a more common name. But in
terms of types of names like algorithms that sort out Hispanic ethnicity, there
is nothing like that that we did.
MR. BLAIR: Okay. Thank you.
DR. WARREN: Okay. David, thank you. We appreciate you dialing in twice to
talk with us.
DR. ESPEY: No problem. Good luck.
DR. WARREN: Our next testifier is from the VA, Sara Temlitz. With that,
Sara, the floor is yours.
MS. TEMLITZ: Thank you and thank you for having me here today. I have
really enjoyed listening to the other speakers, as well as learned a lot. So,
it has been really interesting to me.
What I have brought today is just really a brief overview of what we are
doing within VHA, the Veterans Health Administration, within VA for identity
management of patients presently. I will give you a little bit of information
about where we are going.
Just to start out, this is how we define identity management. The first
definition here is kind of a formal one. It is comprised of a set of business
processes and the supporting infrastructure for the creation, maintenance and
use of digital identities within a legal and policy context.
Then really how we use it, what it means to us is that we have unique
identification for all the patients that we have an interest in within VHA. We
really feel that it needs to have a consistent, really robust matching
capability. I know we have discussed that a little bit previously and we can
talk about that a little bit more. We realize that any matching you are going
to have some identity problems and issues that come from that. So, we really
need to have some tools and methods and processes in place to be able to deal
Really, essentially, it needs to be able to help us to share this
information between the systems that we have to make it effective. So, in VHA,
what we are trying to do with identity management, the reason that we have
implemented it, is to ensure that we really get the highest quality health care
for patients, which means that we have the right data. It is complete. It is
accurate and we can get it easily when we need it.
Patient safety issues are a big concern of ours. We do a lot of work to
eliminate the potential for those and to also monitor them and to react to them
to find out why they are happening so that we can try to be proactive in
finding ways to avoid them and also to support initiatives for sharing data,
not just between the medical centers that we have within VHA, but also with
other agencies within VA and outside organizations, such as SSA and Department
of defense and other agencies as well.
Some of the technical specifications of what we have in VHA for identity
management, we call our unique identifier an Integration Control Number, so I
will use that acronym because we are so used to using acronyms. The ICN is what
we call that. We actually call our master patient index, we call it the MPI.
That is our enterprise index. It contains all the unique patients with their
ICNs and the correlations to the external agencies.
The Veterans Integrated Service Technology Architecture, you might have
heard of before, called VistA, is our suite of applications that supports our
electronic health record.
MR. REYNOLDS: I am going to step out of line and ask a question.
MS. TEMLITZ: Okay.
MR. REYNOLDS: The reason is I want to make sure I don’t miss the hierarchy
of these numbers. So, the ICN is the overall number?
MS. TEMLITZ: Yes.
MR. REYNOLDS: Then if somebody is in three different institutions over
time, they would have an MPI for each one?
MS. TEMLITZ: Here is our obligatory acronym slide here. The DFN is the data
file number, which is that internal VistA ID, which is just what you were
asking. The station number is actually the unique number that is assigned to
each VistA instance. So, if I am seen in a medical center in Milwaukee, they
put me into the local database. The station number is 695 for Milwaukee and my
DFN is my internal number within that database. So, if I then go to Madison or
if I come to Washington, D.C. or wherever and I go to another medical center, I
get that same — I get a new unique combination of DFN and station number as my
internal number from the source system is what we call it concatenated with
that station number.
Those combinations of DFN and station number are what become the
correlations. So, each of the sites that I am seen on, those are all correlated
underneath the integration control number. So, that becomes our overarching
Does that help a little bit?
MR. REYNOLDS: But where did MPI come in?
MS. TEMLITZ: The MPI is the structured — the database, the index that
holds all those numbers in the correlations —
MR. REYNOLDS: It is not a number. It is a database.
MS. TEMLITZ: Exactly. I have a picture of that coming up, too.
FHIE/BHIE is the Federal Health Information Exchange and the Bi-Directional
Health Information Exchange. This is a mechanism that we use to share
information with the Department of Defense. We will talk about that — we will
see that in the diagram, too.
CHDR or C-H-D-R is the Consolidated Health Data Repository and CHI,
Consolidated Health Informatics. You may be familiar with some of those
acronyms. You are all shaking your heads. So, I will move on.
The Enterprise Unique Identifiers or ICNs are integration control numbers.
You were asking earlier about a standard for this number. There actually is a
standard. The ASTME1714-95 standard is for a universal health identifier and on
the slide it even tells you that. It is 16 digits. It is a number, 16 digits,
followed by a character delimiter. We have to use a V, followed by a checksum
that is six digits and you can have even an encryption scheme that is an
additional four digits. At this point we haven’t implemented the encryption
Our current ICN format begins with either a 9 or 10 digit number followed
by a V, followed by the six digit checksum and there is an example of what one
looks like. So, this number that is assigned uniquely to each patient is the
key to linking those patients with other person data across the enterprise. So,
you get one of these numbers.
A little bit more about what an MPI is as defined by the HL7 Version 2.4
standard, so there is a standard that also helps to define what MPIs should
look like and what they should have. I am not going to read this slide because
you have it in your notes. But really what it is telling you is that it can
take these disparate systems as ID domains and correlate them and take these
different entities — they don’t necessarily even have to be patients. They
could be persons of other kinds from other systems and to correlate them under
one unique number.
Some of the functionality that is also defined by the standard is that —
it is a cross reference or an index for these identifications. It provides
methods to retrieve the information for a person giving a set of traits and
demographics for that person. We talked a little bit about that set of traits
that you use to determine what numbers should be assigned and how we determine
that number and I will tell you what we store in our MPI in a couple slides.
The MPI uses matching algorithms. There was a little bit of conversation
about that today, too. Currently, we use a deterministic algorithm. We are in
the process — we have purchased a probablistic algorithm. We are in the
process of implementing that right now and we are going through some of the
processes that were talked about where we are determining which traits we are
going to use, how they will be weighted, what the thresholds are for saying
that this is a match and what needs to go for more of a manual review.
This is more information about how we have implemented our master patient
index. We correlated starting in 1997 the active patients, what we defined as
patients that have been seen within the last three fiscal years from when they
started the enumeration process. We took them from all 134 field facilities,
generally medical centers, clinics and we correlated those under unique
enterprise identifier, the ICN and that was completed in 1998 and that was the
base that we started from.
The ICN is the system identifier. It is not intended to be used as
something that is printed or viewable. It is a system identifier generally. It
could be put on a smart card. It could be put in other mechanisms but it is not
generally something that you would print out and have somebody bring and say,
you know, like you might as a social security number. You are not expected to
memorize it or have it readily available. It is used for system to system
communications for the linkages.
I talked a little bit about FHIE. That is the Department of Defense,
patients are correlated to our ICN using that framework.
MR. BLAIR: F-H-I-E?
MS. TEMLITZ: Federal Health Information Exchange.
We use a VistA. It is like a hybrid HL7 Version 1.6. It was developed by
the VA that is based on the HL7 Version 2.4 standard to do our communications.
That was mentioned earlier. It is a fairly standard communication mechanism.
This is a diagram, pretty simplistic, of what the MPI looks like. So, the oval
one on the top represents the MPI itself, the database that holds the ICNs,
which there is an example of one there and the correlation is underneath it.
If you look at VistA site No. 1 and VistA No. 2, just as I mentioned, the
patient that is in VistA Site No. 1 is given a DFN with that site number and
that is a unique key combination. The same patient at VistA Site 2 has a
different DFN because they were added into the system in a different time. It
is just like a numerical assigned number, concatenated with that site number.
Those two sites are correlated to the one ICN number at the MPI. The
pharmacy laboratory surgery registrations that are listed indicates that in our
circumstance, which is probably easier for us, those all reside within that one
VistA system. They are not just split systems. They are not separate lab
systems. They are all software that is contained with VistA itself. So, we
don’t have specific identifiers for any of those systems. Within a VistA site,
you only have one number, which is what makes it a little bit easier for us.
Then we have the FHIE/BHIE framework up in the corner there that
communicated directly with the MPI to exchange information based on the ICN.
Currently in the master patient index, this is the information that we store
for each patient entry and this is stored for each correlation, meaning that we
take this information from each medical center or facility that a patient is
seen and we store this up at the MPI. Then we also have a primary view, which
is located underneath the ICN. So, really what this is saying is we have used
this information to determine that this patient at Site A and this patient at
Site B are the same one. We are going to keep that information so that we can
see that we made that decision based on these pieces of information.
We used patient names, first name, last name, middle name when it is
available, date of birth, mother’s maiden name, which is one that hasn’t been
mentioned earlier, but it is something that doesn’t change, something that is,
you know, unique to you. So, we use that. Place of birth, city and state also
don’t change. Alternate IDs, SSN. We also have the advantage of having the
claim number for many veterans, which is a unique number. Lots of times it is
their SSN, but deprecated ICNs, which we can explain a little bit later, but
that is if there is a duplicate, one of them is inactivated, but we always
store that with the patient so that you know that other IDs had been associated
with that patient, and date of death, if there is one, and MPI-related data,
which is the ICN itself and correlated IDs, the DFN and station numbers.
Here are some current statistics — yes?
MR. BLAIR: Are you saying — and this may be visible to everyone that can
look at the screen, but are you saying that the MPI does include demographic
data or the MPI is the ICN and the DCF and just the numbers for the site?
MS. TEMLITZ: It does include the demographics. The small set of traits, the
demographic traits that are used to substantiate that identity.
MR. BLAIR: Is in the MPI.
MS. TEMLITZ: Are stored in the MPI, in that index, yes.
MS. TEMLITZ: Some of the statistics, the current statistics for the MPI as
of the beginning of this month, it contains 16.2 million unique patients and
17.2 million correlations, which, you know, that is a bigger number. That is
the difference between how many other sites the patients have been seen at. So,
those correlations are counted as those unique DFN station numbers.
We add approximately 20,000 new patient records each week to the MPI. So,
it is growing pretty quickly.
So, where do we use this number? We have it. It is unique. What do we do
with it? Some of the current applications that we are using that use the ICN
are, as we mentioned again, FHIE for exchanges with data with Department of
Defense and we can do that real time through a remote data view. The next
slide, I believe, shows a snapshot of our computerized record system where you
can see how you can access that.
The computerized patient record system, CPRS, also includes remote data
views and inter-facility consults with other medical facilities that a patient
has been seen at. So, if I present myself in Milwaukee and they pull up my
medical record and have been seen in four other medical centers, you can access
that data, say on health summaries, labs, pharmacies, those kinds of things,
real time by clicking on those connections there.
My Healthy Vet is an application that veterans can use to actually request
RxRefills, prescription refills on line and that is fairly new and we are using
the ICN to do that, to match up to the MPIs to ensure that they are actually in
the database and to find the information about them.
This is not a very good slide. I apologize. But this is like a snapshot of
what CPRS looks like. Up in the right hand corner, where the red circle is, you
can see that remote data. That would be highlighted and when you press that, it
would show you the other facilities where the patient had been seen and allow
you to access information in summarized form for those sites.
Down at the bottom you can see where you can access all the different lab
reports, discharge summaries, surgery. Now because this topic was specifically
about, you know, matching patients and patient selection, we put this slide in
here to tell you a little bit about how we actually go through the process of
collecting this trait information and going through the process of identifying
how patients are linked up.
We do collect the initial identity traits each time a patient presents,
name, social security number, date of birth, gender. A query at that time is
made of real time to the MPI to look for a match and as I said, at this point
it is a deterministic match. It has to match exactly. Every trait that is
provided has to match exactly in order for it to say, yes, this is the same
If that doesn’t happen, it can come back and say there is nobody that even
looks remotely like this and it will add it as a new patient or it can come
back and it can say there are a couple that it looks like it could be. So, I am
not going to tell you that I can match and it goes into a bucket. That is
another technical term, a bucket. It goes over and we have points of contact at
each of the medical centers that have tools, that allow them to review those
and it gives them the information that was entered at their sites and what
resides on the MPI and they compare those and they have the opportunity to pull
in information from DBA, SSA and other sources to make sure that these are or
are not the right patient.
As was previously mentioned, we also have the policy that if you don’t —
if you can’t tell for sure that they are, you don’t match them. We just leave
them up there as two separate. During this registration process if there is a
match found, if the information goes up, it matches exactly. We actually have
the ability to pull down information, some additional demographic information
that was input to other medical centers about that patient and that could be
military service information, income verification information, that sort of
thing. That is an application we call Register Once.
So, if they do make that positive match, it allows them to pull some
information from other sites. Other ways that we do patient selection and
patient look up within that CPRS application, we do have patient lists that can
be set up by physicians, by ward, and patients can be selected that way. And
you also can enter identity traits, such as a social security number, first
name, last name and those will pull up your patients for selection.
Now I am going to tell you a little bit about the structure we have within
VHA to support our identity management function. The first is the data quality
coordinator, who works under health data and informatics, which is part of the
Office of Information within VHA. In that role, they really coordinate a lot of
the activities for our interactions with other agencies within the VA, VBA and
We have a big section that does data standardization. Patient safety is a
really — I guess that is really a big concern of ours and then identity
management is a component of that as well. To drill down a little bit, the
identity management data quality program, which is what I am a part of, really
has taken ownership of the data stewards of this identity data.
We participate in defining business roles, processes, to improve the whole
identity management process, starting from how the information is gathered
about patients to ensure that that we can get the best match that we can. What
happens after that information is collected, how the matches are made, the
processes that happen after the matches are made and to also address some of
those patient safety issues and look at those — the business processes around
those to find out why they are happening.
We also resolve existing data integrity issues on the MPI and at the local
VistA systems, do a lot of coordination with duplicate entries resolving
duplicates if they can find out if they are duplicates, if they are not. If we
have any data quality issues in data standardization implementation if we look
at some fields — you know, we have issues like people will put in mother’s
maiden name unknown or deceased or, you know, to try to alleviate some of those
kinds of issues.
We also do a lot of what we might call marketing or training. We are trying
to really raise the awareness of what the MPI does, the impact of what people
are doing at the local site now has on the national systems. It used to be that
each medical center was pretty much stand alone and what went on in your
database kind of stayed there. But now with so much information sharing, it is
really important that they understand everything that they do at that level
really impacts lots of other systems.
Some of the other things that we are working on, we really have a focus on
data quality because we are part of the data quality component. So, as I
mentioned, we are looking at not only process issues but also in software
design for patient selection, patient data entry, what we can do to improve
those processes to improve the matches. Data cleansing and integrity, I
mentioned that. Patient safety issues and the prevention of those, we have some
real cause analysis going on right now to look at why we are getting some of
the big data issues that we are.
We have mechanisms in place to identify if we may have what we call a
catastrophic edit, which is where a patient entry may be selected and some of
the key identity traits are changed and they actually change the identity of
the patient record, which may have been linked to other ones. The software
detects that those changes have been made and it triggers off alerts to two
different groups to follow up on that and identify why that is happening or why
they might have been doing that.
We do a lot of education on that, too. Why would you be changing these
traits. You know, normally you wouldn’t change the last name and the social
security number at the same time in the same session, unless, you know, you
were actually changing the patient.
Again, identification of data anomalies as I mentioned and some analysis
and resolution of some of those data quality issues that we find system wide.
This is just our resource slide. I put this in here. My e-mail is on here. This
also contains our documentation that is readily available if anybody wants more
technical information or even more user information.
We also have the data quality group, the Data Quality Management Team as it
is listed on here, has a lot of user level information, you know, power point
presentations, user manuals, information It has statistics on some of the
issues that we have going on, reporting on how many patients are being added,
those kinds of things. All of that is available on there, too.
I can let you ask questions or, you know — okay.
MR. REYNOLDS: Are we going to do the last presentation or do you —
DR. WARREN: We seem to have gotten more time. So, do you want to ask about
the VA right now?
MR. REYNOLDS: Let’s go ahead and ask questions now.
DR. WARREN: Jeff is first or do you want to be first, Harry?
MR. REYNOLDS: No, Jeff can be first. I was trying to work the process and
he puts his hand up.
Jeffrey, you are first. I would like to be second.
MR. BLAIR: Help me understand the ICN number a little bit more. Is there
any demographic information that makes up that 16 digit number? Is it purely a
random number or is there any intelligence in it?
MS. TEMLITZ: Well, it is not random really, but it is sequentially
MR. BLAIR: It is sequentially assigned. Okay. Other than it being
sequentially assigned, is there any fields in the 16 digits that is —
MS. TEMLITZ: No, and that is part of the standard is that you can’t break
it apart and find out any information about a person that would identify them.
MR. BLAIR: Okay. If that is the case, why have you found it necessary to
supplement using the ICN with a probablistic approach?
MS. TEMLITZ: Well, the probablistic algorithm, why we are going that route
is to help — it is not really, I guess, directly related to the number
necessarily, but when we have new patient entries and we want to know if they
are the same person so that we can match them together to correlate them.
We find a lot of those same things that previous speakers have talked
about. A veteran will go to one medical center and say that his name is Jeff
and then he will go to the next one and say that his name is Jeffrey. For
whatever reason they have a hard time consistently providing the same pieces of
information when it might be obvious to most of us looking at the record, that
they are the same patient. A deterministic algorithm leaves no room for any
variation on — if you spell Jeffrey a different way, just because the
registration clerk wasn’t careful enough to actually check that spelling, the
match won’t be made.
The probablistic algorithm gives us a lot more flexibility in being able to
say theses two Jeffreys, if all of these other fields are the same, our
tolerance will allow those to be matched and determine that they really are.
With the deterministic algorithm, those would be bumped off to a manual
process, which, you know, is really intensive. If we feel that the confidence
level is high enough to tell us that those match, we would like those to match
MR. BLAIR: Maybe the piece that I don’t quite understand is that if you
have the 16 digit number, why don’t you just use that since that seems — is it
not definitive? Is there still a certain percentage of the time when if you use
the ICN number that you either have a false positive or a false negative?
MS. TEMLITZ: Are you asking would somebody bring in their number and just
say, you know, here is my card —
MR. BLAIR: Yes. This is me. Here is my 16 digit ICN number. Is there
anything else that you really need besides the ICN number?
MS. TEMLITZ: We do use other fields for verification. You are talking about
for patient selection and I am talking about like entering a new patient into a
system that hasn’t been there before. That is when the algorithm really comes
in. And the algorithm can also be used for look up. You are right. If I don’t
know my ICN, if I don’t have a card with it, I will give you my name. I will
give you my social security number. I will give you my date of birth and then
it takes those fields and it goes up and it looks for it.
MR. BLAIR: That is how you use that.
MS. TEMLITZ: Right.
MR. BLAIR: I see. It is used by DOD and VA. Any other federal agencies or
any other parts of the country that is using this?
MS. TEMLITZ: Well, I mean, we use it throughout the entire country, you
know, throughout VHA, which is in all of the medical centers, 138 of them.
MR. BLAIR: And DOD uses the same standard ASTM standard number?
MS. TEMLITZ: DOD has their own unique number. We use our framework to
correlate our unique ID with their information. That is what that framework
does. That is a whole other presentation that I would be happy to talk to you
later. I don’t mean to say that I don’t want to answer the question but really
right now it is kind of complicated.
MR. BLAIR: That is good to know. That is helpful. Thank you.
MR. REYNOLDS: The question I have — well, first, thank you. Excellent and
thanks for helping us through it. You mentioned this My Healthy Vet. So, what
do they use to sign on?
MS. TEMLITZ: They get access in —
MR. REYNOLDS: No, no, what data do they use to sign on?
MS. TEMLITZ: Oh, what data do they use? I am not an expert on My Healthy
Vet. So, if I misspeak and anybody can correct me in the room — but they have
a registration process where you can go in and set up your own — you enter
information. Anyone can do it. You could go and do it. It is a web site that
you access and you enter in your registration information.
Right now I believe that the way that this works is that those traits, when
they want to access their information to see if they can get a refill, those
traits are sent up into a query and they have to match exactly. If they don’t,
that gets bumped to a help desk.
MR. REYNOLDS: So, they don’t enter —
MS. TEMLITZ: The ICN. Right.
MR. REYNOLDS: Because really that — if I wrote my notes correctly, that is
a derived unique identifier, not something they are walking around with as a
standard identifier, is it?
MS. TEMLITZ: It is put on our smart cards, but they don’t see it. It is not
a number that they write —
MR. REYNOLDS: That is what I meant. So, it is not like you are walking
around with your credit card and you can read your number off to somebody. They
don’t see it. So, it is a derived number that really connects your records. It
is not a number that I am walking around with as a vet going here is my number.
MS. TEMLITZ: Right. And it doesn’t need to be. You could give us those
elements and we should be able to find it. In the future, what is going to
happen is that the phase of My Healthy Vet, as I understand it is that you go
into the medical center and you are proofed. You provide identification, two
forms of identification with your picture and they verify all of your
information and they give you these codes and then it will be — see more the
interactions between it because then we are going to link your vaulted
information with the MPI and that link will remain.
MR. REYNOLDS: While I am asking this other question, could you put up the
slide — your Slide 10 again. The way it copied, it was all blank to us and I
have some questions but I couldn’t write them down fast enough. What it did was
it blacked out everything on that.
While you are getting that up, the — well, go to Slide 11 first. The
information you have on Slide 11, so that is what you consider all the
information that is needed to really match somebody back to this derived
MS. TEMLITZ: This is a set of information that we have on the MPI right
now. During the process of implementing this probablistic algorithm, we are now
exploring using some other traits. We are using a vendor algorithm. We have
purchased one, which is really unusual for us because all this other software
is VA developed. We are only purchasing the small identity help. We are not
using their tools or anything. So that it is more of a black box we just call
it, that it is not vendor dependent. We are using their expertise to help us
develop an expanded list of traits that we will be using in the algorithm
because it is a more sophisticated algorithm. It can do more things. We have a
little bit more flexibility.
So, we are going to incorporate some additional things we believe and we
are looking at phone number. We are looking at address. We also have something
in here that somebody mentioned earlier. We have a multiple birth indicator
that we don’t necessarily use to match on but we use it as a flag to say we
have some issues with twins and sometimes they live together. Sometimes their
first names are the same. We know that their dates of birth are the same and
their social security numbers can be off by one digit.
So, we really felt the need to have some way to flag those so that we can
say you better make really, really sure that these are two separate people and
not the same ones.
MR. REYNOLDS: What percent hits — on a general basis if you had a patient
name down through, you know, the things that you have up there down through
date of birth, what percent hit rate do you think you get on them?
MS. TEMLITZ: You mean how many matches do we get?
MR. REYNOLDS: As a percentage?
MS. TEMLITZ: To be honest, I couldn’t tell you. I know that the
registration people will tell us that it is really difficult to get an exact
match on all of those fields when someone comes in and just gives them to them.
MR. REYNOLDS: What percent of your inquiries — you mentioned a help desk.
In other words, as we look at this whole idea of matching patients to records
and you just threw out this new idea of a help desk. Okay. So, you know, if we
go to just strictly data and you don’t have a number and you can’t really get
as good a match then at this help desk. So, what — I mean, does it hit — most
of us who run call centers, you know, you whether it is at 5 percent of the
time, 10 percent of the time.
MS. TEMLITZ: You know, I wish I knew that. I should know that.
MR. REYNOLDS: If you get that back to Judy, that would be great. Because it
is back to this whole process again that if —
MS. TEMLITZ: How effective is it?
MR. REYNOLDS: No, I am not going there. I don’t want to go there because it
is obviously very effective for you. I don’t want to ask that question. I am
just trying to understand as we try to build this and we try to get it to where
— because everybody that we have heard from somewhat today is kind of in what
I would call a closed system. You know, it is the VA doing — the VA and then
you heard Texas dealing with the certain people in Texas and you hear the other
people. Then when you talk about — you start talking about NIHN and you start
talking about where we are all going, they aren’t closely knit groups that may
be sending data back and forth. So, I am trying to — the reason I am drilling
down on the data is to try to get a sense of what data does it take, you know,
how much and how broad and, you know, how standard does it take to really start
hitting the match because as soon as we go outside our own little friendly
areas where we have set the rules, all of us, you know, the game is different.
And the game gets real different and then you start bringing smaller doctors in
and hospitals — I mean, you really start getting into a different game. So,
that is no way negative to what you are doing. It is trying to move it to a
So, the thing I was most fascinated with is since you don’t have a single
number, that the person tends to know and they don’t have their smart card,
then you are having to do this consistently. So, that is why I think you then
become not a closed system to me because the person doesn’t have a unique card,
a unique number they are walking around with and so they are having to give you
that information and that information is allowing you to get back to your
uniquely identified number. So, I think you are a very good case for
understanding how often that does or doesn’t work.
That was my question.
MR. HUNGATE: A follow-up on the same content and make an observation.
Does the DOD follow the same standard in its creation of the number
equivalent to your MPI or do they use a different standard, the DOD?
MS. TEMLITZ: You know, I don’t know that for sure. They have what they call
an EDIPI is what one of their numbers is. They don’t have one number that
covers all DOD right now.
MR. HUNGATE: I asked because earlier testimony talked about the issue of
trust and it strikes me that the approach that you have, where the number is
really not visible is more secure than most other approaches so that I can say
that I am somebody who travels a lot. I am not going to live in a closed
system, as Harry described. Your system is closed in the sense that somebody
does have a number. There is somebody, a pre-registration from the prior visit
and the matching problem is to align to that prior visit wherever it was.
It strikes me that I would like to offer a service or patient
identification. I pay a fee on my credit card. I would rather have the security
of being appropriately matched than have the risk of having mismatch with some
other Robert Hungate, of which I know there are several, but they live in
different places. So, it seems to me there is a benefit for a portion of the
nation population to have some identity that gives them the assurance of
getting into an index that properly identifies them. Call it a voluntary
national identifier piece.
Is there anything like that — I have heard that the VA system is going to
be made available in a commercial version and I wonder if that commercial
version will include this patient identity piece.
MS. TEMLITZ: I think what you are talking about is like the office — the
software and the database that we use for our MPI is public domain software and
we recently had some requests for that software in the documentation, as well
as the schema for creating the ICN — and the reason I know that is because
there was discussion about is that something that we can release. The answer is
yes because it isn’t something that you can pull apart to find someone’s — it
is just sequential numbers.
MR. HUNGATE: I think there is a significant portion of the population that
would like to be able to be assured of proper identification. You know, I have
relied on my social security number, but I hear some threats that say maybe
that is not so reliable anymore and I might like a better version.
DR. WARREN: Wanda, did you have a question?
MS. GOVAN-JENKINS: Out of curiosity, before 1998, what patient identifiers
were you all using and ICN now — I mean, what are the benefits and challenges
do you have now for using the ICN?
MS. TEMLITZ: The patients that existed before 1998 —
MR. BLAIR: What date?
MS. TEMLITZ: 1998 is when we finished —
MR. BLAIR: 1998. Thank you.
MS. TEMLITZ: We do have 7 million plus patients that reside on the systems
that haven’t been enumerated yet. We do have plans to enumerate those at some
point, just to have them all have a number. So, they are inactive patients. If
they would become active, if they show up in a medical center or they have some
activity, they are assigned an ICN at that time. So, that is just a note to say
Before we used the ICN, we were dependent on the DFN station number
probably. There wasn’t as much information exchanged between the facilities
really. I think we did some look up space on social security number and name
combinations to exchange data between — I don’t know. But now all of that is
done with the ICN and inter-facility consults, which I kind of touched on, I
mentioned it but I didn’t really say how that works.
As long as the patient is in your medical center database has been assigned
an ICN and the patient at the other medical center has been assigned the same
ICN, they have been linked up, you can request a consult at another facility
and get those results back at your facility electronically, you know, without
any manual intervention required.
So, it has really facilitated a lot of inner sharing between the medical
centers, where we have lots of patients that in a geographical area, they might
get some treatment in Milwaukee and some in Madison and they can easily heed
the results of that and exchange the information. That, I think, has been the
biggest advantage to having the ICN.
MS. GOVAN-JENKINS: Actually when I leave here today, I am going to call my
father and ask him, you know, what is on his card because he is a VA, but you
mentioned that on the card they have the ICN number but then you said they
don’t have — I mean, do they have it on their card?
MS. TEMLITZ: It is on the stripe. It is not printed on the card.
MS. GOVAN-JENKINS: Thank you.
MR. BLAIR: Related to that, now it is 2006, if somebody is honorably
discharged from the military, DOD, they apparently already have that same
standardized 16 digit number, does the VA have to issue them a brand new number
or can they continue to use that standardized number from DOD?
MS. TEMLITZ: Well, certainly they can use that number. You are asking
really good questions and you can’t see my facial expressions, unfortunately.
The reason that I am in Washington, D.C. — I am from Wisconsin, but I have
been at a meeting for the last day and a half with other VA agencies, BBA and
NCA, because we are looking at sharing our identifier that VHA has with these
other agencies in anticipation of the linkage with DOD. We now have real time
medical data exchange when we have the linkage made, but — so, we are doing
some of that, but what we are working toward is this seamless transition from
active duty to becoming a veteran.
MR. BLAIR: So, you are working to do that?
MS. TEMLITZ: Yes, we are.
MR. BLAIR: Then actually then maybe you could also help educate us a little
bit. What are the impediments or problems to being able to integrate the
system? Now here you have a situation where you have the same standard format
that you are using and all it is a matter of accommodating into one system
using the same standard format. What are the challenges that you are facing now
in trying to integrate?
MS. TEMLITZ: Honestly, a lot of them are business line related, lines of
MR. BLAIR: They are not technical. They are business.
MS. TEMLITZ: Technically, you know, we can come up with a solution to have
that done, but, again, the trust issue. It is business processes, what
information we can share between what business rules we have for who can update
what information. All of that needs to be harmonized between the agencies
before we can move forward. So, I think that is kind of where we are right now.
We can map out some technical solutions to do that. But it is getting over
those other obstacles and ensuring that we don’t upset the operations of the —
DR. WARREN: In lieu of time —
MR. REYNOLDS: Do we have another presenter coming?
DR. WARREN: Yes.
MR. REYNOLDS: Let me ask — so, basically, you are about to become a
further model to watch because you are about to open your system. You are not
opening way up, but you are opening it between two — multiple government
agencies that right now have disparate numbers.
MS. TEMLITZ: Right. They still may maintain disparate numbers, but they
would be correlated, which is not what we are doing —
MR. REYNOLDS: And possibly under this ICN or something?
MS. TEMLITZ: Well, or we may just correlate our ICN with their EDIPI, which
in essence accomplishes the same thing.
MR. REYNOLDS: To you then they almost become another site?
MS. TEMLITZ: Yes. In fact, that is how the remote data view does it now.
MR. REYNOLDS: Thank you.
DR. WARREN: Thank you. I wasn’t expecting that last little bit.
The last presenter that we have is from the Social Security Administration
trying to bring this around. This is John — I am not even going to try because
Maria — you will have to say your own last name, John.
MR. CHLUMSKY: Thank you for inviting us today. We will try to run briefly
through this presentation and leave time for questions.
This is Taz Witt Simmons, who works with me and is much more expert in
digging down in to the details of what I anticipate will be some good
questions, having listened to your questions with the prior presenters.
Before I begin, let me just say listening to some of the questions, I think
one key thing to keep in mind here I will sum up in one word; context. I think
when we go to answer some of your questions, the right answer to some of those
questions depends on the context in which it is being applied. As we go through
our presentation, I think that will become more apparent in terms of how we are
coming at this. The context in which we are coming at this issue is we work in
the e-government arena at Social Security. Specifically, how do we
electronically authenticate that we have got the right person on the other end
of the telephone or on the other end of the Internet and allow them to do
business with social security electronically.
The first slide highlights the topics we are going to cover. I will just
kind of run down that quickly. One is the bottom line here for us is the
challenge of striking a balance and that has come up while we have been here
listening. For us the balance is largely between preserving privacy rights, the
security and integrity of the data in our system and also meeting people’s
evolving service expectations.
In doing that, the primary guidance for us right now and it is relatively
recent is guidelines issued by the Office of Management and Budget that define
assurance levels for how confident we need to be that we do have the right
person on the other end of the line. Stemming from those were additional
guidelines from NIST that tried to tie available technologies to those
assurance levels so each federal agency didn’t have to try to do that on their
own so there would be some consistency.
We will review SSA’s implementation of those guidelines. I will share with
you for us what are sort of rules of thumb as we deal with people who aren’t as
efficient in dealing with these issues everyday in different parts of the SSA
business process to help them often reengineer what they have in mind doing on
line. A lot of times what we are looking at is entities trying to bring an
existing business process into the electronic environment, but they want to do
that in effect without authenticating anybody would be ideal because then we
get lots of business and it is more efficient. But it turns out that is
difficult to do. We will walk through that with you.
We will give you some examples of SSA’s online services and I will just say
to preface that that we have a very interrelated and interdependent services we
provide in general as an agency with lots of varied customers that people don’t
always think about. Usually people think in terms of social security
beneficiaries, but we also process the way of reporting information for all the
workers in the United States and pass that data on to IRS.
As part of doing that business, we also — that makes the employers our
customers as well. So, there are services we provide to employers as well as
other third parties. For example, we have for a lot of our beneficiaries,
representative payees or folks who aren’t able to manage their own funds. So,
we need to interact with third parties. We also have third party helpers, who
help people file disability claims, more complex tasks and we also have other
federal agencies as customers.
We will lay out challenges in three general areas and those are
authorization, authentication and activation and we will explain more about the
distinctions we make there later and we will tell you about our experience and
we will open it up for questions.
In striking the balance, SSA takes very seriously its stewardship of public
funds. That includes the fact that the baby boomers we all hear are getting
ready to retire, but from our perspective, the wave has already begun because
we don’t just provide retirement benefits. So, that wave that is moving along,
we are already getting to experience the impact of providing survivor’s
benefits and children’s benefits to the spouses and offspring of those baby
Some of those baby boomers, many of them become disabled before they reach
retirement. So, we are already seeing those cases and the retirement wave is
just beginning. In order to do that with as with the rest of the Federal
Government, we are not getting lots of additional staff resources and other
kinds of resources. We have got to find ways to become more efficient and we
keep doing that but one of our hopes for the future is that we can do more
business online electronically with more customers in more settings and help
offset some of that wave coming through.
We are also very concerned about protecting the information that has been
entrusted to the agency to preserve people’s privacy and people’s service
expectations are changing. People are increasingly expecting they should be
able to do business with us online or over the phone if that is their preferred
service channel. We have got to rise to the challenge of doing that. That is
easier in some areas than others.
I am not going to get into it too much, but the OMB guidelines I referred
to were issued back in December of 2003 and it was OMB Memo 0404. It lays out
four levels of assurance and just to summarize those, at level 1, there is
little or no confidence that the asserted identity is valid. For us that is
kind of an irrelevant category. For us the two primary ones we are concerned
about are level 2 and level 3. Level 2 says there is some confidence that we
have got the asserted identity as valid.
Level 3 is we have high confidence that the asserted identity is valid and
level 4 is there is very high confidence in the asserted identity as being
valid. That is a pretty high level to hit. So, we are not too concerned about
that on the whole because we wouldn’t do enough business at that level to make
it worthwhile at this stage.
There you are talking about things like PKI certificates at the level 4 and
they are just not ubiquitous enough to be practical for us in the short run. In
terms of the levels, under the NIST guidelines, which were issued in 6/2004 and
on the slide we have got the reference if you need to go look it up for some
At level 2, we are talking about what we call single factor authentication
and those factors are either something you know, something you have or
something you are. At the level 2, you need one of those factors and to give
you examples, a lot of what we just saw in the prior presentation in terms of
names, social security number, place of birth, those are things you know.
Things you have would be things like a PIN and a password, some sort of a
token, a soft token or a hard token and things you are are biometrics of
various sorts. At level 3, you need multi-factor authentication, which means
you need two or more of those things. So, you need some combination of
something you know and something you have or something you have and something
you are. You get a little more assurance that you have got the right person on
the other end.
In terms of SSA’s implementation of the guidelines we have received — and
I have to say SSA had some of its services online before the guidelines came
out and happily we didn’t find ourselves in an uncomfortable place when they
did come out. We were all heading in the same direction.
In our implementation, before we put any application up, we have to do
privacy and security reviews. In effect, we have to certify and accredit — I
am sorry — in the security reviews, that is really part of our infrastructure.
At least every three years we look at our technology infrastructure that
provides Internet services, for example, and we certify that it meets all of
the requirements to be secure.
As we are putting up individual applications within that environment, we
need to do authentication risk assessments and that is, I think, the thing we
are focused on mainly here today. In order to do that, first we have to
establish the general functionality of the application, exactly what is it
going to do and how is it going to work. What is the user experience going to
be like? What are they going to see on the screen? What are they going to
provide to us? How does that business work from end to end?
When we have got that laid out with the project team, my staff facilitates
a discussion with them to walk them through the OMB guidelines and the NIST
guidelines and establish what seems to be the appropriate assurance level for
the application the way it was designed and come out the back end with
recommendations about at what level we need to authenticate people and how we
are going to do that.
Sometimes, frankly, that comes out in a way that people aren’t happy with.
They find they are at a very high level and we have got tools that help them go
back and look at what aspects of their business process caused them to bump up
to that level so they have the option to go back and think about retooling and
how this might work. So, they help strike that balance between privacy and
Having done that, sometimes we find ourselves in a place where we know we
are taking calculated risks. So, we look at risk mitigation strategies. An
example of that is, for example, will we allow people to do electronic change
of address. We will send a physical mailing to the address of record saying
that that — we have taken that action at the person’s request and we have had
occasions where we get a phone call saying I didn’t do that, the kind of cases
that are most typical — and this happens in our field offices occasionally as
well as — an estranged spouse coming in, maybe a divorced father, who is
trying to redirect the benefit check of their disabled child. There are all
kinds of situations out there and we see them all.
So, we have to allow that that could happen and, again, striking that
balance between making it easy for people to do business with us the way they
want, that understanding that everybody is not well-intentioned.
The rules of thumb we share with folks as we walk them through these
facilitated sessions as we are telling them to start thinking about their
applications, because the OMB guidelines are good, but they can be difficult to
work through on your own. They are kind of voluminous and so are the NIST
guidelines. But as basic rules of thumb, the things that tend to cause things
to bump up the assurance ladder are if the application is only going to collect
data from the person and bring it into SSA and we don’t typically let that data
go directly into our master records. Somebody is going to typically look at it.
We are talking about an assurance level 2.
The big thing that bumps you up to the next level is usually if we are
going to disclose some information or propagate some information that already
exists in our records to the screen, then you are in real danger of moving up.
An example of this was in the first implementation of our online change of
address application. That was all PIN password based. But one of the challenges
we have is that for a lot of our customers we don’t have a lot of repeat
contact with them in the course of the year or even over several years. If you
are going to change your address with us, you may never change your address
with us, having given it to us once, and if you do, that might be the only time
you ever do it.
In that situation getting the PIN and password from us is a convoluted
process that involves a physical mailing, chances that you will remember that
password the next time you go to use it probably aren’t high. So, there was a
lot of pressure to get usage of that application up and so there was a lot of
push to move it down to become knowledge based. We just ask for names, social
security number, a few other things and do it that way.
We had difficulty doing that and that is one of the things that led us to
change our tools to help people better see what was causing things to bump up
because it turned out the main problem we were having and the way we were
talking past each other was nobody ever said retool the application. They just
said figure out a way to do this knowledge base. The easiest thing was all we
had to do was stop putting our address of record on the screen when we asked
for the new one. All of the sudden we could drop down a level and that solved
that problem. But it took us quite awhile to figure out how we weren’t asking
each other the right questions.
Moving on, there are examples of the kinds of services we have on line. You
can change your address on line. You can start or change your request for
direct deposit of your benefit checks. You can request a statement of benefits
be mailed to your address of record. We do benefit statement mailings — was it
age 22 and above now?
PARTICIPANT: That is the social security statement.
MR. CHLUMSKY: And you can also view benefit information online. The
challenge areas for us are three. I mentioned authorization, the first question
for us if you come in on the Internet, for example, first we have to figure out
do we even have an account for you to access.
One of the challenges in this area is that people will assume we know a lot
more about them than we do and depending on what stage of life you are at, we
know more or less about you. We know more about our beneficiaries than we know
about workers. With our beneficiaries, we can ask you things like, you know,
what is your monthly benefit amount within a certain number of dollars.
But you would be amazed when you ask people things like what is your
mother’s maiden name, how often they answer is not something that matches our
records. Often our records do say something like — or place of birth unknown
or people might know their mother’s name was Phillips, but they aren’t quite
sure how it was spelled. So, in terms of doing knowledge-based authentication,
we have had difficulty with things that you would think were fairly common
knowledge and you could get about anybody pretty easily and yet the individual
doesn’t know. So, that is a challenge.
The second challenge here is authentication. Having established that we
have got a record here that goes with somebody by that name, now how you going
to show me that that is you. Are you actually the right person? The primary two
ways we do that now are knowledge-based, which involves shared secrets of one
type. These are the single factor things we talked about. What do you know?
For the most part, we have been relying here on using tolerances in terms
of doing matches. So, we are not using fuzzy logic at the moment, but what will
allow you to be a little off. We only match a certain number of characters or
something. We are exploring using fuzzy logic, but there are some issues there
and I think the right answer there is going to come back to the issue of
context. By that I mean depending on what assurance level we think we need,
given the risk of a mistake here. Maybe in some cases we are willing to go with
a fuzzier set of logic for the match than others because the risk of a mistake
is smaller. But we are still thinking that through.
We also issue user IDs and password, which then puts us a multi-factor
situation and one that is both something you know and something you have
because we gave it to you. It is also something that most other people
The third area is activation and that is probably a little more transparent
to the customer, but for us this is an issue of efficiency and for the
customer, it could be that things move a little quicker for them, though they
might not know it. This is really if we go through asking all these
knowledge-based questions and activating an account and saying, okay, somebody
has come in. They have given us this information. There is an account here. Do
we have to go through that entire process again internally to reestablish all
those links or do we in effect establish that we have activated this record the
next time we come in. We could do some short cuts within our computer system to
make this all go faster.
Our experience so far is that we have got a very high level of confidence
so far that in terms of what we have done to date to authorize and authenticate
and activate accounts. That has been going smoothly. Our online service use is
growing and it is growing fairly steadily and dramatically. Between FY 2004 and
FY 2005, for example, we had a 300 percent increase in our electronic services
We moved up from in 2004, 550,000 transactions to 1.7 million in 2005. We
feel like this activity is in its infancy. So, it has got a lot of potential
for growth. Having said that, we are also constantly monitoring the activity to
maintain the integrity, security and privacy. So, we are watching to see — we
didn’t know initially we would have these issues with mother’s maiden name, for
example. So, we are constantly looking at the data, trying to figure out where
people are dropping out of the system or being knocked out of the system and
trying to figure out why that is happening and do we need to tweak it further.
One thing I will mention based on the questions I heard earlier before we
open this up for questions is that there are issues with private credit bureaus
and we are exploring using other third party sources to get additional data to
do knowledge-based activities. We are partnering with the General Services
Administration. They have got the Federal Government lead for trying to explore
some sort of a federated ID across the Federal Government. So, we are
participating in that.
One of the things we heard from third party sources that are trying to do
some of these linkages is that, in fact while a lot of us rely on social
security numbers to match across various databases from different sources, they
tend to be more dependent on things like telephone numbers. They are aware of
the problem with people — a lot of people using the same social security
number and that is not a new problem. That problem has existed since the
inception of the program. In fact, if you go to social security online and go
into the search engine and were to type walletsocialsecuritycard, you will find
an item on one of our history pages that talks about — was it the late 1930s
or early 1940s, Woolworth’s issued or started selling wallets and the
manufacturing of the wallet to help people better understand the kind of things
you could put in your wallet, produced a facsimile of the social security card.
I think it may have been the secretary of the head of the company in fact.
So, that number exists in our instructions to our employees as a
compromised number as late as — that history site will also tell you that as
late as 1978, there were still 12 people reporting earnings on that number
Back at the beginning of the program, people weren’t quite sure what social
security was, weren’t quite sure what a number was, but, boy, they thought that
was a great bonus that came with that 25 cent wallet. They got a social
security number, too and saved, especially in a rural area, probably a trip of
miles on horseback.
PARTICIPANT: Has anybody ever requested benefits?
MR. CHLUMSKY: I am sure they have.
We do have what we call a suspense file. We do these earnings postings
every year and we do our best to give employers the right information to give
us their information in the right format. We keep talking about exchanging
information between computers, but for the most part that information didn’t
get in there, except through somebody’s keystrokes, based on somebody’s
handwriting. Especially the further back you go, the less accurate some of that
data is. So, there are always problems, either people deliberately reporting on
the same number, someone else alluded to illegal immigrants, sharing numbers.
That happened. Or people mistakenly transposing digits. That happens.
We have some fairly sophisticated algorithms that that part of social
security uses to try to sort that stuff out, but inevitably that suspense file
creeps up every year in spite of our best efforts. We hold those and at the
time people come in to file for benefits, if their earnings record shows what
look like unusual years of no earnings or deceptively low earnings, we will ask
them if they can help us reconstruct were they working and can we find that in
the suspense file. We are always looking for ways to improve that process as
One other thing I will share and then open it for questions. Context is in
terms of the kind of data we can ask people for and expect they will be willing
to share with us. We have done some internal surveys with our potential
customers and somewhat to our surprise, when we asked them about the kinds of
information they might be willing to give us, in order to do business with us
electronically, I guess not surprisingly 90 percent or so of them say that if
we ask them about their name and their social security number and that sort of
thing, information SSA already has about them, they have got no problem with
I think it is about 70 percent said that if we were to ask them about other
information that some government agency has on them, that they would be okay
with that, too. So, a driver’s license — I am not sure about the 70 percent. I
will double check that, but it was somewhere in that range. Something like a
driver’s license or some other information that they probably assumed the
government shares, they don’t have a big problem with that. But when we asked
them about things like sharing with us credit card numbers, bank account
numbers, 4 percent say they are comfortable with that.
You have to keep that in mind that that is their perceptions of what they
might be willing to do versus once they get in there and they are trying to do
a transaction, but I come back to the context issue. I think a lot of it
depends on who they are doing business with and does it feel right. If they are
coming with us and they are trying to set up direct deposit, they probably feel
pretty comfortable giving us the routing number for their bank because
otherwise how else are we going to do this.
If they are coming to change their address and we want their bank routing
number, well, why do you need that? And if you are going to VA or someone else,
someone who is providing you with health care services, if you are used to
providing them with a credit card number in order to get services, you might be
willing to provide that credit card number to authenticate yourself because it
feels right in that context. But why does social security need that from you?
So, I think that is something to kind of keep in mind that people’s
reaction might depend on in what context you are asking for it and does it
intuitively make sense to them. So, having said all that, I will throw it open
for questions and Taz will help me answer.
DR. WARREN: When you talk about information and context, I am wondering if
that isn’t one of the key issues. A couple of the other presenters have talked
about trust levels when they were looking at ID as a context. So, this context
may have a real critical piece with that.
I just wanted one piece of information and if you don’t have it, that is
okay, but about how many new social security numbers are issued a year?
Ballpark number, not anything close.
MR. CHLUMSKY: I really don’t know off the top of my head.
MS. SIMMONS: Most of the social security cards are issued that are new that
are issued are an enumeration of births. So, when a child is born — so that is
how most of the social security numbers get issued.
MR. CHLUMSKY: We can get that and e-mail it to Maria, though, if you want.
DR. WARREN: That would be good. One of the questions we have had in the
past has been if social security number was talked about, about being a unique
patient identifier, would we have enough numbers, how much would it cost to
issue them or if we created a new number, how much would it cost, you know, to
create the new number and then dispense it out. That is probably a question
Stan would ask.
With that, I will open it up to questions.
Jeffrey. I am sorry. He holds his hand up first.
MR. BLAIR: First of all, I am really pleased that you have made the move to
more of an electronic environment and because of that some of the things that
were concerns about the use of social security number as an identifier within a
health care setting, that NCVHS identified I think it was eight or nine years
ago — I guess it was eight years ago — maybe some of those limitations or
constraints either don’t exist anymore or have been mitigated. So, for example,
now that you have it in electronic form, do you now make social security
numbers available with a check digit?
MS. SIMMONS: You mean like a checksum to check it to make sure the digit is
MR. BLAIR: Yes.
MS. SIMMONS: No. No, we don’t.
MR. BLAIR: When somebody passes away, is it possible that that social
security number can be reissued to a new child or a new person?
MS. SIMMONS: We have never reissued a social security number, to the best
of my knowledge.
MR. CHLUMSKY: No, we haven’t.
MR. BLAIR: At that time when we were looking at it, there were situations
where there duplicate social security numbers. Do you know what the status of
that is at this time?
MR. CHLUMSKY: You mean multiple people using the same number or one person
having multiple social security numbers?
MR. BLAIR: Multiple people having the same social security number.
MR. CHLUMSKY: We don’t have multiple people that we have issued the same
number to, that as I said earlier using the Woolworth’s card is one example.
MR. BLAIR: — verify that now that hadn’t been in existence eight years
MR. CHLUMSKY: Well, going back to what we have heard from third party
vendors, people are always worried about big brother, but if you look at the
private sector and the information the private sector shares with each other
for various purposes, whether it is the credit bureaus or selling information
to each other for purposes of mailing lists and other purposes, whether you are
checking videos out of a video rental facility or buying pizzas from a pizza
delivery service, there are third party data aggregating companies that pull
that data together and even in cases — and these are the folks that say that
they tend to rely more on things like people’s addresses and not necessarily
just a current address, but what addresses have you ever had, what phone
numbers have you ever had. For them that kind of data makes it easier for them
to differentiate between individuals, individuals in the same household,
potentially individuals using the same social security number.
MR. BLAIR: Let me ask my question a little differently then. Within the
last eight years, what processes or procedures, especially now that you are
electronic, are you able to do to try to verify that an individual is validly
identified with that particular social security number that you weren’t able to
do more than eight years ago?
MS. SIMMONS: We have an internal system that is electronic that controls
social security numbers, the applications of the number and the issuing of the
number and it has been more than eight years. I couldn’t tell you exactly how
many years, but I think it was back in probably in early eighties when that was
put into place. Before that, was there a possibility that someone could have
gotten the same number because it was done manually? Yes, people are human. It
is possible that we could have issued the same number to more than one person,
but since we have gone to the electronic, I don’t know that we have issued the
same number to more than one person because we have it all in an internally
MR. CHLUMSKY: And those numbers are all mailed out from a central location.
They are not distributed locally anymore.
DR. CARR: I am just looking at — to the question of how many specifically
OQA stated in FY 1998, SSA issued 2.4 million original social security numbers.
Is that helpful?
MR. CHLUMSKY: Electronic services? Thank you.
MS. GOVAN-JENKINS: Because of identity theft, have you all thought about
perhaps — I just thought about this — adding a letter to our current social
security number in order to make it less invasive?
MR. CHLUMSKY: There have been a lot of proposals. Congress is constantly
thinking about whether to try to mandate additional — to make social security
cards more tamper proof, for example. All of those things tend to be very cost
effective — cost prohibitive and it is not just the numbers, not just with
social security but anything else. The main thing in the authentication arena
is what kind of proof did you have in the first place that you were given this
number to the right individual.
So, when we talk about social security number as an identifier, it really
isn’t and it never has been. It has become kind of ubiquitous in the private
sector as for the shorthand way to try to differentiate people but social
security has never provided the assurance that that is a hundred percent sure
because as we said we know there have been compromised numbers. We do
everything we can to keep those records straight but we have never promoted it
as a national identifier.
MS. GOVAN-JENKINS: Well, if you thought Y2K was bad, try changing the
social security number. It is out there everywhere. Everybody uses the social
security number in some fashion. Some of them legitimately. Some of them not.
But IRS, SSA, VA, every medic, almost everybody you go to get medical service
now will ask for your SSA. Credit reporting is done by SSN. So, all of that
would have to change if we changed the structure of the SSN.
MR. CHLUMSKY: It is used a lot in the private sector and you are not
required to give it to anybody in the private sector, but they are not required
to give you the service you are asking for either. So, people tend to give it
DR. WARREN: Any more questions?
Thank you very much.
MR. REYNOLDS: Thank you. Very, very interesting.
DR. WARREN: Okay, Harry. It is yours.
Agenda Item: Subcommittee Discussion
MR. REYNOLDS: The next part of the program is obviously for subcommittee
discussion. So, the first thing I would like to do is make sure that we spend
at least half of the 15 minutes of the time on what we just heard and what we
want to do next.
One of the things we had kicked around was the idea of — well, first, I
think we need to answer have we heard enough to start drafting some thoughts.
Second, if so, then, you know, what is our time frame that we want to shoot for
to try to bring something forward out of it for consideration.
So, Judy, let me let you start first.
DR. WARREN: Well, the notes that I was taking is I thought it might be
useful if we again asked HL7 and ASTM to come talk about the standards they
have for identifiers, that at least that would give us some of the technology
pieces behind it.
Several people have been asking about DOD. So, I didn’t know if we wanted
to know what they were doing or whether the response we got from Sara at the VA
that there seems to be this group coming together under the federal
architecture that are eventually going to link in with the DOD. Do we leave it
at that or do we really want to hear from them?
Steve, don’t leave yet. Was it the IHE? Okay. The IHE effort which is
really looking at interoperability and sharing data across systems, that they
might be appropriate to bring in.
DR. STEINDEL: Judy, we discussed that in the NHII Workgroup yesterday,
about bringing in them and I think it would be very worthwhile for NCVHS to
hear from them and I think we need a discussion of exactly where and who.
DR. WARREN: Okay. Those were my thoughts of testimony that we have not
DR. STEINDEL: With regard to the FHA, obviously, this is not going to be a
factor because I think our next meeting is in April. They are undergoing some
reorganization changes and I don’t think we could get a designated speaker, you
know, for the next month or so, just because of those changes.
DR. WARREN: Okay.
MR. REYNOLDS: I have got some other thoughts on this matter, but others of
the committee, comments?
MR. BLAIR: I wonder — and this is a question — do we have enough
information to begin to start to draft recommendations where we could get full
get full committee approval in June? Or is our target date for that going to be
the full committee meeting in September? If it is September or later, will it
still be of value, given the fact that the nationwide health information
network prototypes are going forward and part of those involve matching
patients to their records? So, will our recommendations still be of value if
they come in September or December or are we facing a situation where if
whatever value we may have would probably need to get out in June? So, that is
an open question.
MS. FRIEDMAN: I would like to just follow up on the timing issue and I
don’t know the answer to this. I have been sitting in on some of the
discussions on the AHIC breakthroughs and also I sat in as an alternate — I am
an alternate on the interdepartmental workgroup. Of course, this issue about
the master patient index and the unique patient identifier is right at the top
of that list. As we all know, those groups are moving very quickly. I don’t
know what the answer on the timing issue is.
Having said that, I think we have information where we can start putting
recommendations together. I don’t know whether we have a full letter, but I
think we have a partial letter going.
So, one possibility is just to keep going, maybe start working on the
partial letter and if we see that things are unfolding so very quickly, we
could maybe crank out the partial letter with — you know, do more to follow.
But at least get a chunk of it in.
MS. GREENBERG: I am just wondering if some of the — I think you are right
and you should know what DOD is doing and probably get more information on the
standards and I can’t remember what the last one you said was. I am wondering
if some of that is just back flow or descriptive fact finding that could be
done in a manner other than through a hearing.
MS. FRIEDMAN: I just thought it was interesting that this is the first time
we really heard about the discrete standards in the way that we heard about
Now, we may have heard that information before, but it sure whizzed by me.
MR. REYNOLDS: I guess I have a process question being new at this. So,
since it was brought up today that a standard exists, can staff get access to
that standard and then us use it by reference in any kind of a document?
MR. BLAIR: Sure.
MR. REYNOLDS: In other words, all we are doing is getting the details of
something that was brought to our attention in a hearing. So, I would like to
— I mean, so that is a possibility.
DR. WARREN: I think that is a very distinct possibility, you know, getting
a hold of those documents and doing our own analysis and then bringing that in
to the April meeting or even start sharing that by e-mail prior.
MS. GREENBERG: Then if you have questions, you could follow up.
DR. COHN: I apologize. I may be saying things that are completely either
redundant or off point. But obviously there is a difference between standards
on a unique identifier, which I think is a number of the things that you are
all referencing, if my memory serves me right, versus what we are doing, which
has to do with patient locators and matching patients.
I think they are substantially different things.
MS. GREENBERG: They actually use a standard for their master patient index
in the VA.
MR. REYNOLDS: We are not recommending any standard. We are referencing a
standard that they are using.
DR. COHN: That is fine then.
DR. WARREN: As part of the technical solution for a unique patient
identifier, they referred back to those two standards. So, it is in that domain
that we are looking at it. But I still agree with Harry. It is something we can
look at offline, analyze it and decide whether or not we need any testimony
MR. REYNOLDS: Well, yes, because what I think I found interesting, Simon,
since you weren’t here for that discussion, was the standard called for like a
16 digit number. Okay? So, I think it is relevant in the fact that if the
standard is out there, a certified standard, not the standard would be
You know, you have got the social security number that is 9. You have got
other things that are other thing and now you have got a standard out there
that is being used by the VA that is up to 16. It is just —
MS. GREENBERG: Well, that includes the check digit.
MR. REYNOLDS: Yes, I know. I know.
MS. GREENBERG: Maybe I am wrong about this, but, Jeff, you may have — you
know, the report that was done for the national committee you said it was eight
years ago. Solomon Apovu(?), is that the one you were thinking of?
MR. BLAIR: Oh, good. Your memory is excellent.
MS. GREENBERG: It seems to me it had information and it may be on our web
site. It had information then about this ASTM standard.
MR. BLAIR: Well, I don’t remember whether it had the ASTM standard — I
don’t even know if the ASTM standard was even done at that time. It was an
assessment as of that time.
MS. GREENBERG: So, this has been around for awhile.
MR. REYNOLDS: Let me jump in for — if we could just adjudicate whether or
not Judy and Maria and Donna have — through process, have the ability since it
was mentioned to access it and use it if we have them put together something to
flesh it out more than we heard today because I mean it is — the words are
there. It is a standard. It is not something that anybody — we would be
adjusting necessarily. It would be something we are referencing. We may need
more words on it.
I am talking process now. I think we will need to — you know, to go back
and forth on whether it is going to be in there, whether it is worthwhile,
whether it makes any difference. But I am just talking about using it as an
asset right now.
MR. BLAIR: I almost feel like the greatest value we could contribute at
this point is that we have heard from the networks that are reasonably
well-developed, that have come up with probablistic approaches. We have heard
directly or indirectly from a vendor that many of them use, that has developed
algorithms that are at least accepted by some of these networks, but we have
also heard from a diversity that we may be the only forum that has heard from
not only those entities but we have heard from the VA. We have heard from folks
that are not using those algorithms. We have heard from folks that are
developing their own and we have heard from folks that are looking at matching
patients to their records in different use cases and settings.
That has a tremendous amount of value because for us as a nation, if those
prototypes go forward, ,those prototypes while there is some diversity among
the prototypes, there is some homogeneity among them as well. The testimony
that we have received, I think, adds diversity to whatever those prototypes
might be able to offer. That may be very, very important.
MR. REYNOLDS: One of the things I would like to then put on the table is
that we ask Judy and staff to go ahead and put together what we have heard,
group it together, whether they be recommendations or group it together so that
we could have some kind of a consolidated document for our April meeting, to
make sure that we at least start doing this.
One of the things I think we — and I will take the credit — we fell short
on on some of the stuff that we were recommending the other day, was that we
heard so much information over time, that we weren’t grouping it up along the
way in ways that we could keep ourselves in context. So, when we solve it,
everybody has to go way back to what we all agreed to or didn’t agree to,
thought or didn’t think.
So, I think some of the subjects that we are tackling are broad enough and
I agree totally with Jeff. We have heard a very diverse set of people come and
talk about matching records to records. Let’s don’t even go with patients to
records right now. Let’s go with records to records because that is what we are
really dealing with in the end is information about somebody matched in lots of
disparate ways that it comes in and it gets dealt with. So, that is what I
would like to see because I firmly agree — and Simon and Jeff and I have
independently had some discussions on it. If we listen to what is happening out
there — and I know I have personally met with IBM in North Carolina about what
they are doing, I believe these kinds of things injected into those processes
now sometimes almost as information, even if it is not a full layer yet is
going to be very helpful in the end game of where this country is going to go.
Because there are four sets of people out there right now that are going to say
something and that something is going to have — it is going to have been
fleshed out over a month or it is going to be fleshed out over three hours, but
the point is it is going to come out.
So, I would like any comments on whether or not having Judy and the staff
go forward would be the right thing. Judy, you have your hand up.
DR. WARREN: Well, I just wanted to bring up one more potential speaker that
we might want to bring in in April. Eight years ago, we had Solomon Apovu come
in and brief the committee. He has stayed on top of this issue in the
intervening eight years. In fact, Wanda was looking for someone with the
Federal Corrections Department and his name floated up because he does deal
with the Illinois State Corrections Agency. He is also at ER and does some
So, I don’t know if we want to bring him back in as an update on what he
originally did. I mean, I chose not to bring him in at this time because we had
other people that we had not heard from. So, that is something else to
MR. REYNOLDS: Since we have kind of given you the ball on this, if you feel
that would — so if we had him come in and present, but you still had this
draft — in other words I don’t —
DR. WARREN: Oh, yes, we will have the draft.
MR. REYNOLDS: I don’t think we can wait. Then what he does or doesn’t say,
does or doesn’t effect that draft. At least we are still moving because I think
the time frame is key.
Marjorie, I think she is going to comment on this and then, Jeff, I will
MS. GREENBERG: I was just thinking you might ask him to review the draft.
MR. REYNOLDS: That is exactly what I was going to say.
MS. GREENBERG: He might say, oh, well, you don’t seem to know about this if
you don’t have that.
DR. WARREN: That approach feels better to me.
MR. REYNOLDS: Because again I think the key point is we are asking you to
draft a summary of what we have heard in the hearings that you think would be
something worthwhile. We are not — the reason I am not terming it a letter is
we haven’t decided what we think yet on that. So, we are drafting together and
I would recommend —
MS. GREENBERG: Findings.
MR. REYNOLDS: Yes, findings. I guess one of the things I have learned
recently in this is maybe after each meeting, whoever owns that subject maybe
ought to be doing maybe a synopsis for all of us to keep us in the loop, just
as a general thought. Because we have so much going on and there are so many
MR. BLAIR: I so much agree with what Marjorie just said and what you just
said. So, let me add — so let me pile on and add to that a little bit. If we
have our best initial shot at at least having our list of findings where we
could share that with Solomon and he could comment, supplement, add, clarify,
that could be such a fertile testimony and besides he has got — you are right.
He has been focusing on this and I think he would be an excellent person to
The other piece that I am thinking of is that in terms of the findings and
in terms of the of the role that we could play, how could we be helpful. I am
having the impression — and maybe when we do the findings, it won’t turn out
this way, but I have the suspicion that when we do the findings, there is going
to be a group of findings, mostly the information we have gotten from the
existing networks that have used the probablistic approach and the algorithms
and those findings will wind up showing areas of convergence or potential
convergence and that is good. That is probably going to be similar and support
the prototypes that are being done.
But in addition to that, I think with the testimony we received, we are
also going to find a group of findings that look like they are not converging,
but they represent sectors of our health care delivery system whether it is VA
or Indian Health Service or areas that are focused on research or different use
cases, where there is not convergence. Both of these have great value and I
feel like this is where we add added value in parallel, where we complement —
I am using the word “complement” — where we can complement the work
that is being done by the prototypes.
MR. REYNOLDS: Make sure we get everything we need to do today. If there is
no dissenting voice, then we need to make a motion or do we just have Judy
DR. WARREN: I have one question. In my preliminary thinking about of what
the structure of what this letter looks like, I keep going back to the
structure that we did on the e-prescribing letter because that really laid it
out very clearly. So, that is what I have been thinking about, what I have
notes on. Is that agreeable?
MR. REYNOLDS: And, again, we will be happy to work with you on that. That
MS. FRIEDMAN: I think that is one of those things we learned from the last
letter, that we needed to have some kind of observation and tee it up to
provide context for the recommendations.
MR. REYNOLDS: Okay. Let’s move to our letter, the letter that is in play.
MS. GOVAN-JENKINS: I have received in the research of looking for
different, you know, people with, you know, correctional — the process of
having — in the correctional system, I received several e-mails. So, I can
summarize the e-mails on their process on what identifiers they are using in
the correctional system.
MR. REYNOLDS: Marjorie, again, so I can learn, are we able to include such
things even though we do not hear them in hearings?
MS. GREENBERG: Sure. It is information gathering.
MR. REYNOLDS: Again, I am trying to learn.
MS. GREENBERG: In fact, as I have mentioned in the past, information
gathering is not covered really by the Federal Advisory Committee Act, but we
usually do it in a public setting because it is a good way to get the same
information to everybody and ask questions.
MR. REYNOLDS: That is good. Just trying to learn what we can or what we can
or can’t ask for.
Our letter, one of the things that Jeff and I talked about today about the
letter is one of the things that we would like to consider doing is rather than
calling this HIPAA ROI, which invokes many things. It invokes political things.
It invokes people going back and looking at history. It invokes emotion. It
invokes lots of things.
This is really HIPAA lessons learned and the things that need to get
continued focus and it is also things that we would hope would be taken in
consideration as any other regulation were to come out. But that three letter
nomenclature rings a bell. So, it puts people in many categories. So, you can
say exactly the same kind of things, but when you are talking about what
actually did or didn’t occur, what was realized or wasn’t realized, in the
first place there was a lot of discussion early on about what it was, but there
was never really a template that said so after x years balance it against this.
There is also findings that we have, for example, that it was set up as
expected but some other things need to happen to have it go the full thing. So,
for example, our very first recommendation says that it would be good for
providers to adopt the non-claims transactions. Now, the way it was originally
set up in the regulation, they didn’t have to adopt them. So, going in and
saying whether there was ROI on that adoption for those, especially the ones
that they are not having to do, starts bringing up issues.
So, all we are saying maybe we should change the flavor of the letter to be
more progressive about what should go on from this point forward, rather than
necessarily going back and taking it apart and maybe pushing some things that
without really getting into dramatic detail, you can’t necessarily defend. On
the other hand, you are giving recommendations.
DR. COHN: I have been around for a long time, in fact, even when HIPAA was
passed. I actually don’t in any way disagree with any of the direction — I
would actually ask the subcommittee, we have a couple of options in how we
proceed with HIPAA this year. I mean, one is is that we produce a letter for
June. Another is that we have an annual report that we are mandated to send to
both Congress and the Secretary of HHS relating to progress of the
implementation of the administrative provisions.
The question is is obviously writing a letter is different than producing
an annual summary that may also include all of these other main points. So, I
just sort of lay it on the table that, yes, we can come up with a letter
focused on x or we can somehow, you know, talk about a lot of these things in
the frame of a report, but with key things about really how we are going to
make this even more successful than it already is or however you want to frame
MR. REYNOLDS: No, no, I got you. You had actually mentioned it — I read
the last report. So, I got a copy of the report to read and I feel that the
things — and I could use some help from staff and others — I feel that this
report is a state of the union of HIPAA. I feel that the things we had in the
letter reference some of the same subjects, but are much more focused that
something needs to happen to make it go. So, when I read this report, this
report is a story of which some of these items are mentioned, but not as far as
to say so here is what is recommended to do. The last two I read were more of a
story painting the picture of what the journey has been.
Whereas, these six things that we identified are six things that we think
need to be addressed.
MS. FRIEDMAN: We also don’t have very many lessons learned in here either.
MR. REYNOLDS: No, no, because if I read — what is interesting if I read, I
could take most of the current report that we did in September of 2005 and copy
it. I am not saying that in any negative or positive way. So, what I am saying
is I am not sure that any of those went as far as our letters tend to go. The
other thing is our letters to the Secretary give him and his environment a
chance to deal with what they were responsible for, rather than necessarily at
the same time — that is just another thought. Not right or wrong or good, but
just — yes, Marjorie and then Jeff.
MS. GREENBERG: I think you would do both. I mean, if you do a letter, you
also would include that in the report probably.
MR. REYNOLDS: That would be fine.
MS. GREENBERG: But I think it would be — if you feel there are some things
you really want to highlight, it would be done better by also doing the letter.
Otherwise, it could kind of get buried in the report, but I think it would
belong in the report.
MR. REYNOLDS: But I think, Simon, back to your earlier comment and then,
Jeff, I will turn it over to you, we should go ahead and start preparing the
report, our annual report anyhow. September is when we usually tend to do it,
then we need to get moving.
MS. GREENBERG: Oh, yes, this is a timely issue.
MR. REYNOLDS: It is just whether or not we take these pieces out and do it
twice, not really twice, use the same thing in two different ways. One may be
as a story and the other as direct as possible.
MR. BLAIR: Simon, when Harry and I were thinking about this and we weren’t
sure which way we wanted to go and we were going back and forth and, you know,
should it be in the report, should it be a separate letter and we began to
think about it and we began to think of the issues and the problems and a lot
of things. One of the things that kind of tilted us back to a letter, but not
to — as Harry pointed out, this would be a little bit of a different focus.
The lessons learned is — the letter calls for some action and it not only
calls for some action that is needed to help, to try to finish things in terms
of HIPAA to make it more successful and there are some actions that are needed
there, but when we changed the character of the letter to lessons learned, it
also winds up pointing out that there are some issues here in the way things —
the way we looked at things over the years. It is we. I mean, we looked at
things this way, where we are about to head into clinical standards. We are
about to head into terminology standards. We are about to head into
harmonization of standards, a whole array of other issues.
The letter gives us an opportunity to get that — to really highlight that
out with a little bit of — if there is action that is called for, then there
is a focus. So, I think we could put it in both. We could do the letter and we
could also include it in the report, but the letter does call for actions not
only to improve HIPAA but also to put us in a better position with the other
MS. COHEN: Maybe I would slice this up a little differently and, obviously,
I don’t know exactly what this year is going to hold, but it is really a
question of how we unveil all these pieces and I agree you there is a place for
— I mean, it seems to me there is a couple different pieces we have. One is
efforts needed to assure successful implementation of HIPAA. That is a piece.
Then there is also called lessons learned, which is really a much more of a
— it is a different question. I mean, it is basically learning for the last
ten years. We began to write that in 2002, Jeff, when we — I mean, we are just
now getting clinical standards. We have been getting into clinical standards
since about 1998 and I think we wrote a letter that talked about some of that
back then. So, it is not a new thing.
I think my own view is that the lessons learned may find itself much more
appropriately in an annual report than it would be in a letter. It is just of
conceptually that — you know, somehow if the point of the letter is, by God,
there is — you know, HIPAA, a lot of things are going along well. Other things
really need to be optimized and we really need to do x, y and z, try to meld
that in with a bunch of lessons learned.
MR. BLAIR: So, you are still saying — because Marjorie said something,
which really kind of was something that Harry and I were thinking, too, is that
if you put it in the report — I think, Marjorie, your words were, in some ways
it might be buried and won’t get the attention.
DR. COHN: Let me frame it maybe a little differently here. I think that the
things that need to happen need to be in a letter. I agree with you and it is
probably a June time frame. I am actually wondering if at the September time
frame, whether there may be an occasion marking the anniversary of HIPAA, at
which point a discussion of lessons learned might be very appropriate
conversation to have and I would rather hold it for something more like that. I
agree with you. It shouldn’t be narrated. I am not saying if we move to June,
it might not cross and we may not see that it actually all comes together. I
just think that the messages are very different about —
MS. GREENBERG: I am not quite sure how the timing is going to work out
here. I think Simon and I are on the same wave length here, but one more time
of the week, but it seems to me that if you want kind of a crisp letter that,
you know, makes recommendations or gets attention, you would want it to be, no
more than two pages or something so that you can refer to the findings and to
the lessons learned as being included — you know, you could just highlight
them and then refer to them being included in more depth in the actual annual
report. You would have to have both done at the same time.
MS. FRIEDMAN: I would like to pick up on the flavor of not getting the
lessons learned lost and buried in this annual report that is a cut and paste
job from the previous year, by and large, anyhow. I say that partially because
of I am viewing the world from where I sit now and trying to get out the HIPAA
modifications, next round of modifications and things like that. The world has
changed a lot as we have all observed. On the ten year anniversary is
appropriate to say not only, you know, we have really made it work but some of
the things that might need to be done differently now or that, you know, we
have learned that certain things do work in certain cases and certain things
So, I would just — my vote is to not let that get lost in the report and I
see no harm in duplicating it in a letter.
MR. REYNOLDS: So, let’s see if we can come to a conclusion today and then
we can get ready for tomorrow morning.
So, Jeff and I will take off line with Maria and put together — we already
have a letter that had six key focus points. We would go ahead and adjust that
so that it comes back to this group as a letter that would be complementary to
an annual report that may be the ten year look back or whatever, that we would
also be working on at exactly the same time. Okay, with a plan of that. So that
in June we could have a letter, but it would be in context as to how it relates
or April, we could come back with the letter, at least have fleshed out how in
relation it will be to the annual report.
Then we are looking at July or September to have the annual report done.
But not deal with either one of them, you know, in a vacuum. Make sure that we
can explain as we do each one, how they are related to each other so that
everybody can be comfortable, that we have got a good journey.
MS. FRIEDMAN: I would invite — in an effort to get the wisdom from the
collective intelligence in the room here, I would invite people to send us what
they think the lessons learned from HIPAA are, to e-mail Harry or me, so we can
just kind of keep a list going. I think that makes the process more efficient,
but I also think this is the last meeting we are going to have for awhile, it
would just help move things along if people sent us their thoughts.
MR. REYNOLDS: Okay. So, for purposes of letting everybody get out of here
as prescribed, is there any other business we need to do today. We will be back
together, obviously, bright and early tomorrow morning.
Thank you very much.
[Whereupon, at 5:40 p.m., the subcommittee meeting was concluded.]