Responses to the CMS RFI on National Healthcare Directory

In response to CMS’s RFI on a National Healthcare Directory (responses were due Thurs 12/6/2022), over 600 responses were submitted (around 50% of these were part of two major cut/paste campaigns, making the responses difficult to navigate on We reviewed and summarized the responses by industry segment. We also excerpted statements and linked to notable responses directly to their links on the web site.

If you need background analysis on the CMS RFI itself, catch up on our previous post breaking down the proposed design of a National Directory, history of the concept, use cases, and a summary of the questions posed.

When associations represent a portion of an industry segment, for convenience, these were included in the same row (e.g., American Medical Association is listed under the ‘Providers’ row). Not all responders are listed on this page due to the sheer volume of responses. If you’re looking for a particular organization’s response you can search for them directly using the Browse Posted Comments feature on

SegmentKey ThemesNotable Statements and Links

38% of Responses

Qualified Support
– Reducing administrative burden only happens if all entities use the directory
– Telehealth, LGBTQ care needs
– Provider referrals
– Credentialing and enrollment
– Data submission must be automated
– Directory should refer back to authoritative sources when possible
– Multiple affiliations and contractual relationships can be complicated
“To reduce physician burden and improve data accuracy, CMS should collaborate with industry-operated pre-verified data sources with established physician engagement channels.” American Medical Association

“Unless all health plans agree to participate in and use the information submitted to an NDH, it is likely it will become yet another directory for which physician practices must provide information.” American Academy of Family Physicians

“There is strong concern that a NDH would be duplicative of data collected by CAQH, PECOS and other similar types of provider directories.” American Academy of Dermatology

“While healthcare providers can supply the necessary information and, therefore, drive some of the basic directory content, we must emphasize the infeasibility of large healthcare organizations entering and maintaining provider data manually. The process for submitting, validating, and updating directory information must be automated and standardized.” Cleveland Clinic

“Like other shared utilities for the public good, we believe operational efficiencies will flow from a registry hub as the trusted source of truth for identifying, disambiguating, locating, validating affiliation, and establishing routing preferences and conditional logic associated with provider lookup.” Intermountain Healthcare

“A challenge is a referring provider practicing at multiple organizations. Careful consideration will need to be given to how to manage multiple addresses, referring from multiple places or the handling of multiple hospitals where the providers have privileges.” Mayo Clinic

“Providers may not have all the information necessary to provide requested data. What is CMS plan to ensure requirements are specific to provider? For example, each provider or payer must provide data where they are the “source of truth”. Payers must provide data re: network configuration and provider status specific to each product line.” Quest Diagnostics

Additional Comments from:
American Academy of Pediatrics
American Association of Nurse Anesthesiology
American Clinical Laboratory Association
American College of Obstetricians and Gynecologists
American Occupational Therapy Association
Planned Parenthood Federation of America
Texas Medical Association

13% of Responses

Qualified Support
– Finding providers
– Selecting health plans
– Names, specialty, address, phone, org affiliation, insurances
– Telehealth, LGBTQ care needs, race/ethnicity, languages
– Data accuracy concerns
– Some misunderstand patient data as included, expressed privacy concerns

“One information challenge Leapfrog has observed is the variation among facilities within the same healthcare system and among facilities in a multicampus hospital regarding both the services provided and progress toward meeting Leapfrog’s standards.” Leapfrog Group

“I have often come across such other problems as … Ambiguity over whether all physicians within a physician group or facility accept the contracts with health plans that the group or facility as a whole accepts, such as for facility fees.” Patient Advisor

“At a minimum, we urge any national directory to include accurate contact information, services and specialties, and information, where relevant, about plan participation. We would encourage information about availability, including whether the provider is accepting new patients and a rough estimate of the wait times for appointments.” Medicare Rights Center

“The key to the success of an NDH is accuracy. Providers and plans must be held accountable to keep the information updated.” US Public Interest Group

5% of Responses

Qualified Support
– Concern that NDH becomes ‘another place’ to submit
– Bi-direction integrations with CAQH, NPPES, and other systems
– Timeliness and accuracy
– Telehealth, Health equity, SDOH, LGBTQ care needs
– Provider accountability
“There are various use cases for provider data related to credentialing and enrollment, provider directories, and network maintenance … If an NDH does not address all these needs and require participation broadly across the industry, it is likely that an NDH would become another place for providers to submit information, resulting in more administrative burden for providers and payers.” CAQH

“The value of the NDH would be its comprehensiveness. If the directory can only be created for a subset of providers (for example, Medicare), it would not alleviate the need for duplicative systems and processes and would be much less valuable.” Elevance

“One of the challenges that CMS would face is the fluidity in provider data. In implementing an NDH-style directory CMS should consider the provider burden in maintaining their provider data and take steps to mitigate any additional work for the providers.” Fallon Health

“Our experience with provider directory accuracy efforts demonstrates that this is a monumental effort. Leaving seemingly minor items unresolved could lead to continuing data issues and increased burden on providers and payers to manage both those items not included in an NDH as well as the items unresolved through the creation of an NDH.” Humana

“The NDH should be built with the capability to exchange data with existing provider directory solutions as well as databases that may be established in the future. These linkages would include health insurer and group health plan directories, Medicare, Medicaid, states (e.g., licensing databases and health agencies), and other data sources (e.g., CAQH, NPPES).” UnitedHealth Group

Additional Comments from:
AmeriHealth Caritas
CareFirst BCBS
Oscar Health
Health Tech Vendors and Consulting

26% of Responses

Qualified Support
– Need for incentives, accountability for various data
– Critical of NPPES accuracy, others suggest to build on top of NPPES
– Leverage data from EHRs and other third-party sources
– Directory utilities already exist
– Digital endpoints
“CMS should implement a governance process that eliminates the need for basic curation, ensuring it is clear who is responsible for owning and updating data elements. For example, individual providers could be responsible for updating their contact information, locations where they practice, etc. and payers could be responsible for updating information about accepted insurances.” athenaHealth

“From a policy perspective, we believe that the most important consideration in developing a multi-party system is ensuring that the rules governing the system hold each participant accountable for the timeliness and data under their control.” Consumers’ Checkbook

“Technologies that reduce administrative burden and eliminate redundancies are critical to addressing burnout and prioritizing patient care. This effort presents an opportunity to improve navigation and better serve communities across the country more efficiently, effectively and equitably.” Doximity

“Over time, requiring providers to update their NDH information would be optimal. EHR systems should implement the reference standards and enable connection to the NDH API into their foundational platforms as an update to reduce the need for additional mapping and conversions.” Google

“Vast provider data already exists within payer portals, Independent Physicians Association (IPA) rosters, health system rosters, and medical boards databases. If CMS can accurately aggregate existing data, the NDH can reduce the manual data entry burden on providers by building upon verified, highly confident data sources.” RibbonHealth

“Without strong incentives for providers to keep the data up to date, technology changes are unlikely to improve data quality.” Smart Health IT

“As stated earlier, the more publicly accessible data the NDH can provide, the more valuable and adoptable the NDH becomes to a broader audience. Having a roadmap to illustrate the establishment, and long-term evolution, of the NDH, is about more than simply improving provider directory accuracy. Including data essential for consumers to make informed decisions about their health care will increase the value of the NDH.” Quest Analytics

Additional Comments from:
CGI Federal
Defacto Health
Komodo Health
Leap Orbit
Orderly Health
Open Referral Initiative
Press Ganey
State and Local Governments

4% of Responses

– Collaborate with state initiatives
– Leverage data collected by states
– Provide data required by underserved populations
– Provide grants to states to update systems to conform with data exchange requirements
“CMS should consider collaborating with states and their data sources, and funding state involvement and integration with NDH as a contributor of curated, authoritative data on the organizations and professionals regulated by the state.” California Health and Human Services

“Reducing state and federal provider network reporting requirements, or the frequency of reporting for payers that supplant their provider/service directories with the NDH, could incentivize payer engagement.” New York City Department of Health and Mental Hygiene

“For equity, the NDH should include many of the community resources accessed by underserved and economically challenged populations. Tennessee Department of Health

Additional Comments from:
Arkansas Insurance Department
Alaska Department of Health
Illinois Department of Insurance
Minnesota Department of Health
State of Colorado
Washington State Medicaid

Health Information Networks/Exchanges

2% of Responses

Qualified Support
– Partner with HINs
– Identify, use authoritative sources
– Will be challenging to transition from decentralized to centralized
– QHINs to be represented in NDH
“NYeC supports the goal of a national system of health information exchange that can be realized through the Trusted Exchange Framework. In that context, we suggest that CMS engage with both existing and established health information networks such as the SHIN‐NY as well as Qualified Health Information Networks (QHINs) in efforts to integrate health information networks in an NDH.” New York eHealth Collaborative

“In addition, we recommend the NDH, eventually and incrementally, include and incentivize as many healthcare entities as possible, including providers, public health entities, and community-based organizations.” CRISP

Additional Comments from:
New Jersey Health Information Network
Sequoia Project
Other Associations

11% of Responses

– Good data and reduction of burden could be an incentive to adopt
– Phased approach
– Focus on using a directory to support interoperability use cases
– Endpoint discovery is difficult
– Leverage pre-existing trust models to support new data exchange use cases
“The Drug Enforcement Administration under the Department of Justice requires providers that are authorized to prescribe controlled substances to go through an identity proofing process to that meets the LOA3 standards. Currently, about 800,000 providers have been through this process. We believe that CMS could leverage those identities, and the identity proofing process contained therein, to start building a new provider directory.” CARIN Alliance

“The NDH MVP must include digital endpoints. The lack of an authoritative central directory of digital endpoints creates a significant gap in our ability as a healthcare industry to move many critical interoperability initiatives forward.” FHIR at Scale Taskforce

“At a minimum, and consistent with national accreditation standards for credentialing, CMS should require a standard process for primary source verification of practitioner credentials before appearing on an NDH.” NCQA

Additional Comments from:
Association of American Medical Colleges
Federation of State Medical Boards

All industry segments agree on the objectives of increasing transparency for patients and reducing provider burden, however, most are skeptical on whether these are achievable by NDH. Many recommend a phased implementation to prove early value before scaling (but also disagree on initial use cases). Many wonder whether CMS has the authority to make NDH a true one-stop shop for all lines of business (including non-CMS funded lines) for provider data.

It will be interesting to see how CMS synthesizes the diverse and voluminous feedback, and how that feedback will inform future rule making and decisions that will impact how patients and healthcare industry stakeholders find care, find coverage, exchange data, and how they manage the data and meta-data to accomplish those tasks.