CMS & HHS Issue RFI on National Health Care Provider Directory; Comments Due December 6

Published October 07, 2022

The Centers for Medicare & Medicaid Services (CMS) and Health and Human Services (HHS) have issued a Request for Information (RFI) seeking comments on establishing a National Directory of Healthcare Providers & Services (NDH) that could serve as a “centralized data hub” for healthcare provider, facility, and entity directory information nationwide. The RFI provides background on the NDH concept and perceived benefits for providers, payers and consumers.

The departments seek input on the current state of health care provider directories and steps that CMS could or should take if CMS concludes that adequate legal authority exists to establish an NDH and proceeds to do so.

The RFI asks the following questions that could be of interest to group health plan sponsors:
  • What types of data should be publicly accessible from an NDH?
  • Are there specific strategies, technical solutions, or policies CMS could pursue to encourage participation in an NDH by group health plans and health insurance issuers offering group or individual health insurance coverage for programs or product lines not currently under CMS’ purview?
  • What provider or entity data elements would be helpful to include in an NDH for use cases relating to patient access and consumer choice (for example, finding providers or comparing networks)?
Comments are due December 6, 2022.

Note: The Consolidated Appropriations Act, 2021 (CAA) requires: 
  • Each group health plan and health insurer with a network of providers to maintain a database of providers on a public website that lists the name, address, specialty, phone number, and digital contact information of each provider that directly or indirectly participates in the network. 
  • Each group health plan and health insurer will establish a process to verify data in the directory at least every 90 days, beginning with plan years that start on or after January 1, 2022. 
  • Each health care provider and health care facility should have in place business processes to ensure the timely provision of provider directory information to those group health plans and health insurers.

To address part of the issue of inaccurate directory information, the CAA established consumer protections for incorrect provider directory information identifying a provider or facility as in-network for an item or service. 

Further rulemaking is forthcoming for the provider directory requirements of CAA,  titled “Requirements Related to Surprise Billing; Part I.” An interim final rule has been released; the final rule has not yet been released.