ONC for Health Information Technology “Direct White Pages” Pilot

A recent Power Point Presentation was made by the ONC for Health Information Technology on a
“Direct White Pages” Pilot

The pilot proposes to address the issue of developing a Provider Directory as one means of implementing messages between users in a ‘Direct’ environment, that is, in an electronic environment.

Since the concept of a Provider Directory in order to implement messaging in an EHR world has been debated for years without (except for a few rare cases) any notable successes, the ONC wants to pilot with the experience of states to develop, in their words, a ‘Direct White Pages’ of Providers.

In order to do this they propose to use as a data collection vehicle state-level Medicaid attestation data, specifically the ‘Direct’ addresses of providers attesting to the State’s EHR incentive program for Medicaid.

Is this a good idea?

We have had the opportunity to review one state’s Medicaid data to see what kind of information would be appropriate for such a test. There are a number of qualifications: First, one state does not make a country and so the results could be skewed because the state is not ‘randomly’ chosen. And this particular state has had some difficulties with Medicaid enrollment and reimbursement. However it is a reasonable large state with more than 20,000 active Physician Providers.

Second, not all Provider Physicians are Medicaid enrolled and we could only account for about half the active Physicians in our database that were Medicaid enrolled in that state.

Finally, we are not sure how many of the total Provider enrollees in the state represent ‘Medicaid attestation data for the State’s EHR incentive program’. What we reviewed was the entire database of Providers enrolled in the Medicaid program.

Nevertheless there are some interesting results from our analysis of the emails in the file:

  • 87% of the records we reviewed were Providers, that is, the record had
    an indivdual’s name and 13% of the records were facilities
  • Of the Providers only 32% had an email address, 68% did not
  • Of those with an email address 60% were duplicate emails..in other words
    there was one email address that was registered for multiple providers..in
    many cases that was a facility that used a central email address for all Providers
    at the facility or a centralized credentialing authority.
  • Another 2% of these emails were addressed to billing companies or had input
    errors (e.g. no ‘@’).

It is of course possible that ‘Direct’ could use a facility email for messaging; however, that would involve ongoing maintenance by the facility and/or by the individual Provider to update information when and if Providers move, retire, become board ineligible or deceased or inactive, etc. The least maintenance effort would be to uniquely tag a Provider with a ‘Direct’ address. That would eliminate the maintenance and follow up effort.

If you do the arithmetic that left 12.4% of the Providers with a unique and apparent individual email. That seems to be fairly low; however, on closer examination that may even be an exaggerated number.

We attempted to scan for whether any part of the email’s address included some portion of the Provider’s last name, first name or any initial. That is not a conclusive way to evaluate the emails because obviously there are all sorts of algorithms in developing an email address; however, some of the email addresses had recognizable names that had no bearing or relationship to the name of the individual Provider. As a hypothetical example you might have a Provider named Robert Jones, MD and the email address is Mary.smith@gmail.com. Now it may be that Mary Smith enrolled Dr. Jones, may be a relative or a dedicated employee, or have some close relationship with the Provider; but in terms of ‘Direct’ addresses and the concern with Patient Privacy with misdirected electronic medical records, it would be problematic to rely on that email address without further information.

Of the 12.4% of Providers with an apparent unique and individual email address, fully 50% of the records had questionable names that did NOT include any portion of the Provider’s name.

The assumption that the ONC is making in proposing the Pilot is that Medicaid files of Providers attesting to the individual State’s EHR incentive program are current and accurate. That may not be an accurate assumption. Rather the emphasis should be made to ‘clean up’ those Medicaid files whether or not they are used for ‘Direct’ messaging.

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September 2020
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