Health Insurance Information

CMS-CCSQ Sup. Health Insurance Info data elements for USCDIv6

Data Elements:  Coverage Period (Level 2), Medicare Patient Identifier (Level 0), Payer Name (Level 2), Plan Name (Level 2), and Group Name (Level 2)

1. Recommendation: Advance Medicare Patient Identifier to Level 2 and add all these data elements to Final USCDI v6.
2. Rationale: Inclusion of these common data elements for nationwide interoperability is essential for such use cases as value-based care, health equity including affordability for lower-income individuals, and enabling patients across the board to determine costs and affordability up front. This Health Insurance Informationdata class is associated with the overall primary and secondary coverage for the individual. In some cases, it may be different from the benefit used for a particular encounter or claim (e.g., worker's comp benefits). We recommend aligning the naming of Medicare Patient Identifier (MPI) with CMS’s use of Medicare Beneficiary Identifier (MBI). While these data elements are already included in the latest FHIR US Core and Consolidated CDA implementation guides (IGs) referenced in the Health, Data, Technology, and Interoperability-1 Final Rules (HTI-1), the implementation community can benefit from more clarity on how to consistently populate these fields—in particular Payer Name and Group Name—as there is variation between what a typical insurance card shows versus what is best used on real-time eligibility (RTE) queries with health plans.

NCQA Recommendations for USCDI v6- Coverage Type

Coverage Type: 

Recommendation type: Modification to existing USCDI element.

Recommendation: Adjust the data element definition and examples to note that coverage type should include product line (for example Commercial, Medicare, Medicaid), product (for example PPO, HMO, POS), and benefit (for example drug, mental health).

Rationale: Comprehensive, and hierarchical, coverage type information allows for utility of the data. One individual could fall into several categories within Coverage Type. For example, an individual may be classified as enrolled in an HMO, but under the current element definition, stakeholders would be unable to distinguish if the HMO is a commercial product. In NCQA’s HEDIS reporting structure, we mitigate this challenge by asking organizations to submit multiple records to indicate if a member is in multiple Coverage Type categories. For example, one member enrolled in a commercial HMO with a drug benefit has three sets of records: one indicating commercial enrollment dates, one indicating HMO enrollment dates, one indicating drug benefit enrollment dates.  It would be more efficient to have one set of records indicating that the member is in Product line: Commercial; Product: HMO; Benefit: Drug. NCQA created a reference sheet (attached) to inform HL7 community efforts to further refine the Coverage Type structure. We encourage ASTP to consider how to make this data element more granular in USCDI. 

NCQA-Coverage Type-SOP.pdf

NCQA Comment on Smoking Status: for USCDI v5

1. Smoking Status:

NCQA recommends updating the element name to Tobacco-Use Assessment to encompass assessment of broader tobacco products beyond smoked products/cigarettes; This aligns with the FDA definition of Tobacco products. We also recommend adding to the examples of items that fall under this element quit date and smoking duration, in addition to the examples of pack-years and current use already included.

We recommend updating the terminology to include LOINC in addition to SNOMED. Smoking status, tobacco-use status, and smoking behavior details (i.e., pack-years) are well defined by LOINC and/or SNOMED.

Comprehensive assessment of tobacco-use and smoking behaviors remain a public health priority and are essential to appropriately providing cessation intervention. These data elements are also crucial for understanding a patient’s eligibility for lung cancer screenings, a screening that is recommended by the U.S. Preventive Services Task Force and that remains underutilized despite its proven effectiveness. NCQA is currently developing measures to incentivize routine tobacco use assessments and appropriate lung cancer screening for those eligible based on smoking history.

NCQA Comment on Coverage Period: For USCDI v5

1. Coverage Period:

NCQA recommends the inclusion of coverage period, the coverage start and end dates, in USCDI v5. This information is essential when sharing any other health insurance related information already included in USCDI for context about the coverage time period and supports assessments of patient access to resources and care, a stated ONC priority. Coverage period is also used widely in quality measurement to assign people appropriately to the measure population. This element is included in the US Core IG Coverage profile as must support.

USCDI v3- "Health Insurance Information" Clarification

The “Health Insurance Information” Data Class currently does not provide applicable vocabulary standards nor guidance regarding the scope of the term “Health Insurance.” Arrive Health is seeking clarification confirming "Health Insurance” includes both medical and prescription insurance. Arrive Health supports the expansion of USCDI to include the new Health Insurance Information Data Class and recommends it accurately encompasses both medical insurance and prescription insurance information.

Comprehensive health insurance information includes medical insurance coverage and prescription insurance coverage. Without requiring prescription insurance information, we are failing to capture the complete picture of health insurance coverage, and as a result, we are failing to capitalize on the innovative technologies and achievements presently available to provide transparency. One of the primary ways patients interact with the healthcare system is through prescription drugs. It is important to be inclusive of both medical and prescription fields given the increasing overlap for items like specialty medications and the growing importance of patients and providers knowing the full medical history.

In the pivotal shift to include insurance information as a new Data Class, prescription drug insurance information is a critical element that must be included to support patient care, disparity reduction, drug adherence, and interoperability. As evidenced by Medicare Part D, comprehensive health insurance includes medical insurance coverage and prescription insurance coverage. Medical insurance information is just one piece of the critical data needed for price transparency. Often, patients have different insurance coverage for medical and prescription drugs. Employers that contract separately for medical and pharmacy require representation of both medical and pharmacy eligibility for interoperability to work comprehensively for their members. Thus, to achieve complete interoperability, prescription insurance information must be included in the Data Class.

Arrive Health strongly encourages ONC to clarify that the USCDI v3 “Health Insurance Information” Data Class includes both prescription drug insurance information and medical insurance information. Thank you again for the opportunity to provide comment on USCDI Draft v3. We appreciate your efforts in maintaining core data sets to promote system-wide interoperability and value your consideration.

Sincerely,

Arrive Health

USCDI-Version-3-July-2022-Final (1).pdf

Policy Number and Subscriber Name

Consider adding data elements for:

• Policy Number
• Subscriber Name

This comment is submitted on behalf of the National Emergency Medical Services Information System (NEMSIS) Technical Assistance Center.

Lantana Consulting Group Comment

Lantana recommends ONC include the Facility ID element in USCDI V3. The post-acute care (PAC) assessment instrument collects Facility Identifier information and standards exist for Facility ID.

Health Insurance Information

This new USCDI V3 data category includes several data elements related to an individual’s insurance coverage for health care.  While the information is valuable and necessary to support interoperability, several of the proposed data elements are not mature enough to be listed as a V3 element.

If you consider the lack of clarity and consistency across V2, C-CDA Templates, and US Core Profiles for representing data elements such as Coverage Type, Member Identifier, Subscriber Identifier, Group Number, and Payer Identifier, these elements do not have sufficiently mature implementability compared to other USCDI V3 data elements.

While we agree the proposed Health Insurance Information data elements are critical to support valuable interoperability use cases focused on getting the right information to the right parties at the right time, without well-formed identifier systems for elements such as payer identification and member or subscriber identifier, and without a single, consistent, accessible vocabulary for Coverage Type, adding this category of information to USCDI V3 will fail. It also will undermine trust in the methodology used to assess the maturity of data elements promoted to the level of a recognized USCDI data element. 

If ONC is in favor of keeping Health Insurance Information in the list of USCDI V3, consideration needs to be given to enabling an effort that supports creation of well-formed identifiers and code systems for these concepts, as well as an initiative to drive adoption across all Health IT standards used to exchange this category of information. 

USCDI V3 Comment 20220429_1.pdf

NACHC Comment

NACHC supports the comment from CMD-CCSQ and believes health insurance information is critical to support patient access and care systems that support appropriate prescribing, referral, and benefits delivery. 

We strongly support the use of the code systems and codes described by the code systems to ensure robust and patient-centered support for patients in the US healthcare system.

See attached document for a detailed summary of all NACHC USCDIv3 comments.

2022-04-30 NACHC USCDIv3 Letter of Support_5.pdf

Health Insurance Information

The Regenstrief Institute supports the USCDI Task Force recommendation to add Health Insurance Data Class to USCDI Version 3. We also recommend including LOINC as a terminology standard to capture concepts related to a patient’s health insurance status that can be coordinated or mapped to the SoPT Payer Value Set found here:  Source of Payer Typology Value Set

Some LOINC examples include 87520-3 Coverage type and 89061-1 Insurance group number.