April 5, 2017: MGMA Labor-H patient matching support letter

April 5, 2017

Dear Chairman Frelinghuysen, Chairman Cochran, Ranking Member Lowey, Ranking Member Leahy, Chairman Cole, Ranking Member DeLauro, and Committee Members:

On behalf of the undersigned organizations, we wish to urge the inclusion of the report language that seeks to end patient safety issues related to patient matching in the House FY17 Labor, Health and Human Services, and Education and Related Agencies (Labor-HHS) draft Appropriations Bill. For nearly two decades, innovation and industry progress has been stifled due to a narrow interpretation of the language included in Labor-H bills since FY1999, prohibiting the Department of Health and Human Services (HHS) from adopting or implementing a unique patient identifier.

The patient matching report language clarifies Congress’ intent while ensuring that the federal government does not impede private-sector efforts to solve this serious problem. The language enables the U.S. Department of Health and Human Services (HHS), acting through the Office of the National Coordinator for Health Information Technology (ONC) and the Centers for Medicare & Medicaid Services (CMS), to provide technical assistance to private-sector led initiatives that support a coordinated national strategy to promote patient safety by accurately identifying patients and matching them to their health information. Allowing ONC and CMS to offer this type of technical assistance will help accelerate and scale safe and effective patient matching solutions.

The absence of a consistent approach to accurately identifying patients has resulted in significant costs to hospitals, health systems, physician practices, and long-term post-acute care (LTPAC) facilities as well as hindered efforts to facilitate health information exchange. According to a recent study of healthcare executives, misidentification costs the average healthcare facility $17.4 million per year in denied claims and potential lost revenue1. More importantly, there are patient safety implications when data is matched to the wrong patient and when essential data is lacking from a patient’s record due to identity issues. The 2016 National Patient Misidentification Report cites that 86 percent of respondents said they have witnessed or know of a medical error that was the result of patient misidentification2.

Patient identification errors often begin during the registration process and can initiate a cascade of errors, including wrong site surgery, delayed or lost diagnoses, and wrong patient orders, among others. These errors not only impact care in hospitals, medical practices, LTPAC facilities, and other healthcare organizations, but incorrect or ineffective patient matching can have ramifications well beyond a healthcare organization’s four walls. As data exchange increases among providers, patient identification and data matching errors will become exponentially more problematic and dangerous. Precision medicine and disease research will continue to be hindered if records are incomplete or duplicative. Accurately identifying patients and matching them to their data is essential to coordination of care and is a requirement for health system transformation and the continuation of our substantial progress towards nationwide interoperability, a goal of the landmark 21st Century Cures Act.

The quality, safety and cost-effectiveness of healthcare across the nation will improve if a national strategy to accurately identify patients and match those patients to their health information is achieved. Clarifying Congress’ commitment to ensuring patients are consistently matched to their healthcare data is a key barrier that needs to be addressed if we are to solve this problem, but not the only one. We the undersigned are committed to working together to identify, and address, the various barriers that prevent patient matching today.

We respectfully request that you include the report language below in any FY18 appropriations bill:

Clarifying the Unique Patient Identifier Ban to Enable Patient Matching
The Committee is aware that one of the most significant challenges inhibiting the safe and secure electronic exchange of health information is the lack of a consistent patient data matching strategy. With the passage of the HITECH Act, a clear mandate was placed on the Nation’s healthcare community to adopt electronic health records and health exchange capability. Although the Committee continues to carry a prohibition against HHS using funds to promulgate or adopt any final standard providing for the assignment of a unique health identifier for an individual until such activity is authorized, the Committee notes that this limitation does not prohibit HHS from examining the issues around patient matching. Accordingly, the Committee encourages the Secretary, acting through the Office of the National Coordinator for Health Information Technology and CMS, to provide technical assistance to private-sector led initiatives in support of a coordinated national strategy for industry and the federal government that promote patient safety by accurately identifying patients to their health information.

We appreciate your consideration and inclusion of this report language and we look forward to working with you to pursue an appropriate solution to enable accurate patient identification and data matching in our nation’s healthcare system.

Sincerely,
American Academy of Family Physicians (AAFP)
American Medical Association (AMA)
America’s Health Insurance Plans (AHIP)
American Health Information Management Association (AHIMA)
American Medical Informatics Association (AMIA)
Association of Clinicians for the Underserved
College of Healthcare Information Management Executives (CHIME)
Confidentiality Coalition Connected Health Initiative (CHI)
Electronic Healthcare Network Accreditation Commission (EHNAC)
Healthcare Leadership Council
Healthcare Information and Management Systems Society (HIMSS)
Health IT Now Imprivata
Intermountain Healthcare
LeadingAge, CAST
Long Term and Post Acute Care (LTPAC) Health IT Collaborative
Medical Group Management Association (MGMA)
National Health IT Collaborative for the Underserved
Nemours Children’s Health System
Pharmaceutical Care Management Association (PCMA)
Premier healthcare alliance
Strategic Health Information Exchange Collaborative (SHIEC)
The Sequoia Project
Trinity Health