The NPI Final Rule called for CMS to establish a system that would assign a National Provider Identifier (NPI) number to essentially every healthcare provider in the U.S. (HIPAA "covered entities"): now more than 3 million providers and growing. Great. But it was years before CMS released that data for the industry to use. CarePrecise personnel were at the forefront even back then, calling for CMS to release the data. If necessary, we were ready to fight for it, filing our own request under the Freedom of Information Act (FOIA). Federal agencies can't keep such kinds of data from the public. It's the law. CMS eventually looked at FOIA, and at their provider data, and decided that, sure enough, they were going to have to release it. We and our clients were ecstatic; now the industry would be able to produce the complex crosswalks necessary to actually achieve the efficiencies promised by the Final Rule.
Hurray... except CMS decided not to release one of the most useful data points of all. A provider's federal tax number is hardly a private number. Businesses have to give their tax number on every imaginable type of transaction. Employees see the employer's number on their W-2s. CMS's excuse was that sole proprietors and pretty much all individual practitioners would have to give their Social Security Number, or that busy doctors might type in the SSN in the wrong spot. Fair enough, but, as everyone who works with data knows, it's a piece of cake to parse a tax number field to determine if the number is a SSN or a business tax number.In fact, that's just exactly what CMS does in the Other ID fields of the NPPES (National Plan and Provider Enumeration System) database, replacing 000-00-0000 with a string of equals signs.
Instead of just redacting the SSNs, CMS decided it was best just to wipe clean the complete Employer Identification Number (EIN) field -- just in case some uppity docs got... uppity. Many of us have been hoping that CMS would revisit the issue of this gaping hole in the provider data, but it seems that the issue is to be ignored so that it will just go away.
So, here we are, once again, years into it, asking CMS to release non-SSN tax numbers/EINs so that we -- health systems and health plans large and small, clearinghouses, HIT vendors, medical billing and coding vendors -- can make this data do what it was intended to do for healthcare and for the taxpayers.