Morgan Health and Embold Health CEOs: Creating a Centralized Provider Directory Would  Accelerate Quality Improvement, Value-Based Reforms in Employer-Sponsored Market

As policymakers look to raise the standard of care for millions of Americans, establishing a national directory of health care providers and services (NDH) would meaningfully accelerate value-based care models across public and private markets while expanding patients’ access to higher quality care across a range of specialties and geographic markets, Dan Mendelson, CEO of Morgan Health, and Dr. Daniel Stein, CEO of Embold Health, said in a new comment letter to CMS Administrator Chiquita Brooks-LaSure.

The joint letter comes in response to CMS’ recent Request for Information (RFI) on the development of centralized provider and services directory that would serve as a “source of truth” to support more accurate, up-to-date provider information across a range of health care databases, including health plans’ provider directories. Currently, no centralized database exists, leading to persistent data gaps for consumers, physicians and specialists, health plans and employers who rely on accurate provider data for a host of health care decisions – from physician selection, network development and benefit design and quality improvement programs.

“Addressing long-standing quality, affordability and equity challenges in employer-sponsored insurance requires meaningful and targeted federal policy solutions,” Dan Mendelson, CEO of Morgan Health, said. “We strongly support the development of a national provider database as it will serve as an important catalyst for broader adoption of accountable care across the commercial market. By establishing clear standards for data collection and a secure framework to counter cybersecurity threats, CMS can ensure that critical provider information is available and accessible for employers and employees.”

“For years, the country has focused on what we need to do to improve the quality of care without taking the necessary steps to make sure we all were operating with the same set of data and information on who is actually providing care to patients,” Daniel Stein, M.D., CEO of Embold Health, said. “A national provider database would create a paradigm shift in our collective approach and conversation around quality improvement, value-based care and care navigation in support of all Americans’ health.”

Highlights from the letter are included below:

• “…We support the creation of the NDH, noting that this resource will enable:
  • Health plans and plan sponsors to have a more accurate picture of where individuals are seeking care, helping to inform benefit design refinements and network improvements needed to optimize access to and quality of care delivered to members across geographies and specialties;
  • Health plans, plan sponsors, and providers to collaboratively develop more effective payment models that drive accountability for the cost and quality of care delivered to Americans; and
  • Health care innovation efforts to help accelerate adoption of value-based care models, as the provider data in the NDH will reliably facilitate evaluation of providers across public and commercial payers.”
• “A centralized NDH could become the source of truth for all provider-related information, allowing for ease of access for information. Requiring routine updates of a single source of information would ensure that a source of truth exists for all provider contact information and discrepancies do not exist by trying to maintain the same information across multiple, disconnected systems that rely on information from each other.”
• “For employers, an NDH could help advance care navigation improvements within their employee benefits ecosystems. An NDH would provide the foundational information on covered providers and employers could build or enhance care navigation solutions around these data. With this goal in mind, employers can help to increase utilization of an NDH by requiring self-funded plan carriers to have their in-network providers report their information to the NDH.”
• “In building this database, CMS should consider whether required data elements will be extracted from existing databases or if providers will need to validate or resubmit their information, either in a set timeframe or as part of renewing their enrollment with Medicare or Medicaid…Clear guidance should be established for providers submitting new information or renewing enrollments during this timeframe before the complete transition to the NDH is made to minimize risk of incomplete data or data loss.”
• “CMS should adopt ‘best data’ rules to determine the most accurate information in the likely event there is conflicting information from different sources (e.g., site of practice address variation between an individual provider and group practice that includes the same individual provider in its roster of affiliated clinicians). CMS should consider how the NDH will be maintained as the source of truth for both Type 1 (individual) and Type 2 (organizational) providers and specify criteria for many-to-many data mapping relationships to account for providers affiliated with multiple practice locations, or multiple providers in a single practice location.”
• “Cybersecurity, especially in health care, is of the utmost importance when considering the development of an NDH. CMS should prioritize development of a secure framework to protect provider information from unauthorized access, disclosure, and use in order to ensure the integrity of the database. The NDH must also have functionality to avoid cyberattacks against the system itself or any of the users/entities with links into the hub as these attacks would threaten health care operations across the entire country.”
• “CMS can consider multiple design elements to ensure the NDH helps advance health equity. The website and database must be accessible for those with disabilities in accordance with U.S. Department of Justice Guidance for Web Accessibility and the Americans with Disabilities Act (ADA). Additionally, the ability to use the database in multiple languages or have access to translation or interpretation services to navigate the database will be important. Every consideration should be made to ensure all users can obtain the necessary information they need in a way they can understand.”

To view the full letter, click here.