Each individual implementation team weighted the criteria described in section I.D., Process for Developing National Standards, in terms of the standard it was addressing. As we assessed the various options for a provider identifier against the criteria, it became apparent that many of the criteria would be satisfied by all of the provider identifier candidates. Consequently, we concentrated on the four criteria (1, 2, 3, and 10) that were not satisfied by all of the options. These criteria are described below in the specific context of the provider identifier.
#1. Improve the efficiency and effectiveness of the health care system.
In order to be integrated into electronic transactions efficiently, standard provider identifiers must be easily accessible. Health plans must be able to obtain identifiers and other key data easily in order to use the identifier in electronic transactions. Existing health care provider files have to be converted to the new standard. In addition, health care providers will need to know other health care providers’ identifiers (for example, a hospital needs the identifiers of all physicians who perform services in the facility). To meet this criterion, we believe the identifier should not be proprietary; that is, it should be possible to communicate identifiers freely as needed. Moreover, the issuer must be able to reliably issue each health care provider only one identifier and to issue each identifier only once.
#2. Meet the needs of the health data standards user community.
The identifier must be comprehensive. It must accommodate all health care provider types or must be capable of being expanded to do so. Based on our definition of “health care provider”, this includes individual health care providers who are employed by other health care providers and alternative practitioners who may not be currently recognized by health plans. The identifier must have the capacity to enumerate health care providers for many years without reuse of previously-assigned identifiers. To meet this criterion, we believe that, over time, the identifier must be capable of uniquely identifying at least 100 million entities.
#3. Be consistent and uniform with other HIPAA and other private and public sector health data standards in providing for privacy and confidentiality.
Confidentiality of certain health care provider data must be maintained. Certain data elements (for example, social security number and date of birth) needed to enumerate an individual health care provider reliably should not be made available to the public.
#10. Incorporate flexibility to adapt more easily to changes.
To meet this criterion, the identifier must be intelligence- free (the identifier itself should not contain any information about the health care provider). Intelligence in the identifier would require issuing a new identifier if there is a change in that information. For example, an identifier containing a State code would no longer be accurate if the health care provider moves to another State.