Do We Need a National Patient Identifier?

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By Michael Burger, Practice Lead, EHRs and EDI

Interoperability continues to be top of mind for industry pundits and the Office of the National Coordinator for Health Information Technology (ONC). I have long contended that interoperability is not so much a technology challenge as a business challenge. The competitive nature of the business of healthcare delivery is primarily what prohibits the exchange of clinical information. It is a convenient "red herring" to point the finger at the “evil” electronic health record (EHR) vendors for colluding to prevent systems from talking to one another. The real issue is supply and demand. When there is demand among customers to connect systems, software vendors respond by building and selling connectivity solutions.   

That said, patient identification is one area of interoperability where a technology challenge remains. At issue is that there is no standard way to identify patients. For a variety of reasons, medical practices, hospitals, and insurers increasingly are discarding the use of the Social Security Number (SSN) in favor of their own identifiers and algorithms. Lacking a universal patient identifier, a number of commercial solutions vie to be “the” solution. Among others, a strategic alliance between Experian Health and the National Council for Prescription Drug Programs (NCPDP) is a recent entrant in the patient identifier space. Surescripts created a system for matching patients to their records and leveraging that expertise, launched its National record Locator Service. And, the Commonwell Health Alliance provides members with a patient matching service.  

The Department of Health and Human Services is prohibited by statute from spending any funds to create a unique patient identifier standard, unless authorized by Congress. This ban remains in place, and there are varying opinions on whether a unique patient identifier is even necessary. ONC Chief Don Rucker, M.D., was quoted in Politico  as deflecting calls for investment in a national patient identifier during an HL7 meeting on July 13. "We already have one, it's called the Social Security Number," he said. Even assigning everyone a number would not prevent all misidentification errors, according to Rucker. "This has been a discussion point all my 30 years in informatics. Some of this will be solved by biometrics before it is solved by policy."

To compound what is already confusing and contradictory, Medicare is transitioning to a new patient identifier for beneficiaries. Under the Medicare Access and CHIP Reauthorization Act (MACRA), the program was required to stop using beneficiaries' SSNs on their Medicare cards and replace them with a Medicare Beneficiary Identifier (MBI). This was undertaken in response to concerns that using the SSN increases opportunities for identity theft.

I tend to agree with Dr. Rucker at ONC that there is no real need for yet another identification number.  No solution is 100% infallible and the SSN has been “good enough” for many years. But if the Social Security Number is truly not safe to be used as a unique patient identifier, why couldn’t the new MBI be extended to everyone? Congress provided $320 million over four years to pay for retrofitting some 50 million Medicare beneficiaries’ cards. There will be administrative overhead incurred by payers, pharmacies, providers and vendors as they change over to the MBI in their systems. Why not amortize the costs of introducing the MBI across all citizens and solve one of the true interoperability challenges?

This is something Congress should consider. The House Appropriations Committee just asked for a report on the benefits of a system that accurately links a person to his or her medical information, should Medicare require the technology. The Committee also is directing ONC "to engage with stakeholders on private-sector led initiatives to develop" a strategy to accurately link patients with their health information. The issue is real. A potential solution is already available.