Cynthia Grubbs
Director of the Office of Policy and Planning, B
ureau of Health Professions,
Health Resources and Services Administration,
U.S. Department of Health and Human Services
Good Morning. I am Cynthia Grubbs, the
Director of the Office of Policy and Planning, Bureau of Health
Professions, Health Resources and Services Administration, U.S.
Department of Health and Human Services. I am here to speak with you
today on the National Practitioner Data Bank, the Healthcare Integrity
and Protection Data Bank and the Federal Credentialing Program.
The Health Resources and Services Administration (HRSA) -- often
referred to as the “access” agency -- provides medical care and social
services to millions of low-income Americans, many of whom lack health
insurance and live in remote rural communities and inner-city areas
where health care services are scarce. We work in partnership with
States and local communities. One of our operating bureaus, the Bureau
of Health Professions, invests in programs to help make sure that all
areas of the nation and all segments of the population have access to
skilled health care professionals. In conjunction with these tasks,
responsibility for the National Practitioner Data Bank and the
Healthcare Integrity and Protection Data Bank is assigned to that
Bureau.
The National Practitioner Data Bank (NPDB) was created in response to
the requirements of the Health Care Quality Improvement Act of 1986 and
plays a vital role in the important process of health care practitioner
credentialing. It provides verification of sensitive adverse information
about health care practitioners in an efficient and reliable manner,
while at the same time maintaining the security and confidentiality
required by law. Authorized users of the NPDB include State licensing
boards, hospitals, managed care organizations, other health care
entities and professional societies. Hospitals are required to submit
queries regarding staff practitioners every two years and/or each time
they hire, affiliate or grant privileges to a practitioner. The NPDB
receives adverse information on licensure, adverse clinical privilege,
and professional society actions taken against physicians and dentists
from the required reporting by licensing boards, hospitals, and other
health related entities. The NPDB also receives information on medical
malpractice payments, Drug Enforcement Administration actions and
Medicare/Medicaid exclusions taken against physicians, dentists, nurses,
and other health care practitioners. Let me be clear that the NPDB does
not contain information on all health care practitioners, only those
practitioners who have had an adverse action taken against them.
NPDB data is intended to supplement a comprehensive and careful
professional peer review. The Data Bank is used by entities to verify
information the practitioner submits in his or her application for
privileges, licensure, or affiliation. Currently, for example, when a
practitioner applies for employment or for admitting privileges, the
hospital asks the practitioner for a complete practice history including
any malpractice payments or adverse actions. A query of the NPDB then
verifies the information about malpractice payments and adverse actions
for the hospital, or it discloses information to the hospital that the
practitioner may have failed to include in the application.
The NPDB is now considered essential to the process of privileging and
credentialing. Its value has been documented by surveys of Data Bank
customers. Additionally, the NPDB along with its companion system, the
Healthcare Integrity and Protection Data Bank (HIPDB), was recognized
this year as among the “Top 5” information technology achievements in
the public service arena by Excellence.gov, an annual awards program
that honors computer innovation in the Federal government. Major
accrediting organizations, such as the Joint Commission on Accreditation
of Healthcare Organizations (JCAHO) and the National Committee for
Quality Assurance (NCQA), have endorsed the value of the NPDB by
strongly encouraging, and in some cases requiring, organizations they
accredit to access the NPDB in the credentialing process.
The NPDB is not funded by taxpayer dollars, but entirely by user fees.
The NPDB currently covers its costs through fee collection and has done
so successfully for nearly fourteen years. The current $4.25 query fee
is substantially lower than fees charged for databases of similar,
though much less complete, information. Through fee collection, the NPDB
is able to provide information within hours to requesters using the
latest technology to maximize speed, convenience, and security, while
minimizing financial burden to its customers and not imposing any burden
on the U.S. taxpayers.
NPDB Aggregate Data
At the end of calendar year 2003, the NPDB contained 344,708 reports on
individuals. It received 3,256,295 requests for information in 2003. Of
those requests, 445,004 matched information contained in the NPDB for a
match rate of 13.7 percent.
HIPDB
The Healthcare Integrity and Protection Data Bank (HIPDB), created as
part of HIPAA of 1996, commenced operations in late 1999. The purpose of
the HIPDB is to combat fraud and abuse in health insurance and health
care delivery and to promote quality care. The HIPDB is primarily a
flagging system that may serve to alert users that a more comprehensive
review of a practitioner’s, provider's, or supplier’s past actions may
be prudent. Like the NPDB, HIPDB information is intended to be used in
combination with other sources (e.g., evidence of current competence
through continuous quality improvement studies, peer recommendations,
verification of training and experience, relationships with
organizations) in making determinations in employment, affiliation,
certification, or licensure decisions.
Health plans and Federal and State agencies are required under Section
1128E of the Social Security Act to report adverse actions taken against
health care providers (HMO, PPO, Group Medical Practice), health care
suppliers (Durable Medical Equipment, Manufacturers, Pharmaceutical,
Insurance Producers) and health care practitioners (nurses, podiatrists,
psychologists, etc.) to the HIPDB. The HIPDB collects healthcare-related
criminal convictions and civil judgments entered in Federal or State
court, Federal or State licensing and certification actions, exclusions
from participation in Federal or State health care programs, and other
adjudicated actions or decisions that the Secretary has established by
regulation, such as certain contract terminations taken by health plans.
These same organizations, Federal and State agencies and health plans,
access the HIPDB for information.
The HIPDB provides another resource to assist Federal and State
agencies, State licensing boards, and health plans in conducting
extensive, independent investigations of the qualifications of the
health care practitioners, providers, or suppliers whom they seek to
license, hire, credential, or with whom they seek to contract or
affiliate.
The information in the HIPDB serves only to alert Government agencies
and health plans that there may be a problem with a particular
practitioner’s, provider’s, or supplier’s performance. HIPDB information
is not used as the sole source of verification of a practitioner’s,
provider’s or supplier’s professional credentials.
HIPAA requires that the HIPDB's operation be funded through user fees
charges to health plans and other private entities that are authorized
to query the database. These fees have not generated sufficient revenue
to fully fund the database's operations. To meet the statutory mandate
to operate the HIPDB, HHS has supplemented the user fee collections with
funds from the Health Care Fraud and Abuse Control (HCFAC) account.
HIPDB aggregate data
At the end of calendar year 2003, the HIPDB contained 159,995 reports on
individuals and 3,758 reports on organizations. Of the reports on
individuals, 21,787 were on physicians and dentists, 21,731 were on
registered nurses, and 15,031 were on licensed practical nurses or
vocational nurses. Pharmacists constituted 4,785 of the reports,
chiropractors were 3,532 of the reports, nurses’ aides were 11,804 of
the reports, and psychologists represented 1,203 of the reports. The
HIPDB received 872,211 queries in calendar year 2003. Of those requests,
10,028 matched on information contained in the HIPDB for a match rate of
1.1 percent
VA and the Data Banks
In terms of the use of the Data Banks by the Department of Veterans
Affairs, the VA facilities use both the NPDB and HIPDB. As mandated by
the NPDB’s implementing legislation, a Memorandum of Understanding (MOU)
between the VA and HHS governs the VA’s interactions with the NPDB. The
provisions of the MOU are intended to mirror the requirements the
legislation places on the private sector. VA facilities submitted 31,750
queries and 119 reports to the NPDB in 2003. Of those queries, 25,612
were submitted on physicians and 6,138 queries were submitted on other
practitioners. The VA has submitted 349,223 queries and 940 reports
since the NPDB commenced operations in 1990. For HIPDB, VA is
specifically mentioned in the statute as a mandatory reporter and a
voluntary requester of the information. In 2003, VA facilities submitted
30,836 queries and 1 report to the HIPDB. Of the queries submitted in
2003, 24,958 were submitted on physicians and 5,871 were submitted on
other practitioners. Under the provisions of the HIPDB statute, VA
facilities query the HIPDB for free.
DoD also uses the NPDB and the HIPDB as part of its credentialing
process. DoD submits queries to the NPDB and HIPDB, as well as, reports
adverse actions to the data banks on its health care practitioners.
Federal Credentialing Program
The Federal Credentialing Program (FCP) was developed to replace
paper-based credentialing processes with electronic storage techniques
for easier retrieval of credentials and faster communication of
credentialing information in the Federal Government. In 1997, the
Department of Veterans Affairs, Veterans Health Administration (VHA) and
the Department of Health and Human Services (HHS)/Health Resources and
Services Administration signed an inter-agency agreement establishing a
formal partnership to develop an electronic credentialing database for
the vetting of the VA’s health care professionals.
In partnership, HHS and the VA determined that a certified, trusted
electronic system would result in better credentialing and efficiency.
The resulting software application, VetPro (i.e., to vet (evaluate) in a
Peer Review Organization) allows providers to enter credentialing
information such as education, licenses, and work history into an
electronic, web-based system. A credentialer through primary source
verification in accordance with appropriate accreditation standards
authenticates the data. In addition, the system shares an interface with
the NPDB/HIPDB to allow for seamless querying to the Data Banks. Once
verified, the data may be stored electronically for subsequent
retrieval. Information about health care professionals contained in
these databases is very sensitive, and the Agencies administer the data
consistent with all applicable security and privacy requirements.
By 2001, the FCP was used by the VA in all of the 172 facilities in its
health care delivery network. By 2003, the U.S. Public Health Service,
Office of Emergency Preparedness, Immigration and Naturalization
Service, National Aeronautics and Space Administration, and the National
Health Service Corps had entered into one-year interagency agreements to
participate in the FCP.
However by 2003, the landscape of the Federal government had changed.
The Office of Emergency Preparedness and the Immigration and
Naturalization Service were transferred to the U. S. Department of
Homeland Security. The Division of Commissioned Personnel’s internal
business processes changed, which eliminated their need of the FCP.
These three Federal organizations no longer participate in the FCP.
For these reasons, in October 2003, HRSA transferred responsibility for
management of all FCP-related activities, including the VetPro software,
to the VA, where we understand the system continues to operate
effectively.
Thank you for the opportunity to inform you about the NPDB/HIPDB and the
FCP.
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