The Journey to a Unique Patient Identifier

Once again, Congress decided not to allocate funding for the Department of Health & Human Services (HHS) to begin the development and implementation of a unique patient identifier (UPI), nor have they chosen to adopt the proposed House language to fund an investigation into potential patient-matching technology. Since its first proposal in 1999, funding for this unique identifier has been stymied continually by Congress due to privacy concerns. The bill’s language instead encourages HHS to continue their technical assistance in private sector-led initiatives for patient matching. The bill also calls for the Office of the National Coordinator of Health Information Technology (ONC) to provide a report to Congress detailing ways to improve patient identification (found on p. 123 of the bill linked above). Sadly, it was no surprise to learn that once again Congress chose to punt on a national resolution to this issue.

I have been following this drama for many years, and in those years I have encountered varying arguments both for and against the need for a national UPI. Recently, I joined a new Public Policy Committee workgroup on patient identification for The Healthcare Information Management Systems Society (HIMSS), a community which has long been a proponent for Congress to loosen restrictions on funding for these issues. Their current policy statement expresses their initiative as follows:

“Congress should clarify the Labor-HHS UPI rider and immediately direct HHS to study patient data-matching solutions; such study must include the impact of: implementing a national-level UPI; how a national-level solution might impact locally-based solutions currently underway; and how various levers (federal mandates, public-private collaboration, etc.) impact progress towards solution.”

The purpose of this workgroup is to seek any necessary modifications in HIMSS policy from a more global perspective than just the concerns of healthcare technology and informatics in the United States.

Other entities within the private sector, including The College of Healthcare Information Management Executives (CHIME), have also championed government action. Perhaps the most insightful analysis of patient identification issues was an October 2018 Pew Charitable Trusts Report. This report details industry challenges in patient-matching, citing a 2012 CHIME survey of hospital CIOs who claimed one out of every five of their patients were harmed due to identity mismatches. Other issues, apart from those issues of safety, include an increased potential for fraud as well as possible privacy violations. The Pew Report echoed similar concerns published by the ONC in 2016, based on an industry meeting they held on patient matching and PDMPs.advocates because FHIR is not simply a technology fix, it is a human/language/data/technology fix for the Tower of Babel that is the current Healthcare world.

Partly in response to ONC’s work, the National Council for Prescription Drug Programs (NCPDP) and Experian Health formed a recent partnership. In December 2019, they made the announcement that they had assigned a UPI to every American. While it is unlikely that this feat solved the great patient matching problem, even for just the PDMP space, it is indeed a major step forward in the creation of unique identification methods for patients.

Though I could extend this discussion in far greater detail, I will summarize the big picture of this entire situation in three comments:

1. We do indeed need improvements in patient matching consistency, even within individual health systems, and eventually across all systems. Studies have proven that this paucity in proper patient matching has resulted in many adverse consequences.
2. Technology to enable patient identification matching has improved tremendously over the years and will continue in that trajectory as artificial intelligence, better identity management and new data sources become more ubiquitous.
3. Implementing a national UPI, which some in the industry feel will be the panacea to patient matching issues, is not a trivial undertaking. As someone who was heavily engaged with implementing several national identifiers at CMS, my experience tells me the implementation of a national UPI would take years, cost a great deal, and still would not solve all issues of patient matching. Given the challenges of implementing a national UPI and continuing advances in technology, I begin to wonder whether we really need a UPI at this time or soon. There are existing efforts that could be leveraged in addition to the NCPDP work. The entire healthcare space could perhaps take inspiration from the new Medicare card number which allows for better patient matching, as an alternative to the lengthy creation and implementation of a national UPI.

The Pew Report has clearly and concisely laid out the issues, challenges and potential solutions for this formidable national issue. Given the history of Congressional inaction on this matter, it is critical for HIMSS and similar organizations to promote industry-wide efforts to improve patient matching without committing to a national UPI. Industry and the advocacy community should also continue to lobby for Congress to provide federal funding for improving patient matching. These efforts will go a long way in the push for better interoperability and a stronger federal role in implementing a national patient-matching strategy. Until that occurs, siloed local efforts will continue as the norm, impacting the care quality and safety of patients everywhere.