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  1. Last 7 days
    1. Regarding the comment on the active work on a National Directory FHIR IG, we thank this commenter for pointing this out. Because we have not required the publication of individual provider-level identifiers, we are not considering this IG for the endpoint publication use case in our Program. We emphasize again that because we have finalized an approach in § 170.404(b)(2) that references the base FHIR standard, Certified API Developers have the flexibility to consider using “Organization” and “Endpoint” FHIR resources profiles, such as the profiles in the National Directory FHIR IG, to meet those requirements.

      Specifically mentioning the NDH FHIR workgroup and the NPD implmentation in terms of meeting requirements.

    2. Response. We appreciate commenters' input and suggestions for clarity. We intend for these additional organization details to be used by app developers to help them map organizations to endpoints which, in turn, helps patients find the organization(s) they want to allow an app to access data from. We clarify that facility or organization level identifiers are sufficient to satisfy our proposed publication requirements. Facility level identifiers, for the purposes of certification to these Endpoint publication requirements, include identifiers such as: a National Provider Identifier (NPI), Clinical Laboratory Improvement Amendments (CLIA) number, CMS Certification Number (CCN), or other health system ID. Support for one of these identifier types is sufficient, meaning Certified API Developers are not required to publish individual NPIs as a floor for certification. Different identifiers may be used depending on the customers a Certified API Developer has. We have updated our regulatory text at § 170.404(b)(2)(ii)(B) to more clearly state that “[e]ach Organization resource must contain the organization's name, location, and facility identifier.”

      Patients finding data from EHRs that hold their data requires either NPI, CLIA, or CCN. They are not required to publish "individual" NPIs. But they have to have ONPI or something else that we can link to.