John Quinn
Ernst & Young LLP
HL7 Technical Committee Chair

Testimony given to NCVHS on July 21, 1998


My name is John Quinn I represent Ernst & Young LLP and the Technical Chair of HL7.

My testimony, in general, support the creation of a National Universal Person Identifier. My answers to the specific questions proposed by the committee are:

Specific Questions for Panel 1b:

1. Why or why not have a unique individual identifier for health care?

Speaking from the perspective of my Firm (Ernst &Young) and the providers that I serve, the ability to correctly identify a person is directly responsible to correctly finding a patient’s history and clinical records, and the ability to correctly bill and be reimbursed for services given to a patient. Patient safety and general customer service requires that this also be done quickly.

As provider organizations have merged into larger integrated delivery networks over the last five to ten years, we are finding more time and money being spent in the provider organizations to create information systems that can deal with the status-quo which is several different historical identifiers and identification schemes. Some organizations are attempting to create a new integrated delivery network-wide identifier while, at the same time, accommodating different legacy information system-based identifiers and hard-copy based identifiers on patient charts, film jackets, prescriptions, etc.

A unique individual identifier would eliminate the need over time for new complex MPI systems that have an “approximate or statistically uncertain” chance at matching these different identifiers. These new systems automate the process, reduce the need for a human to research every encounter and, may—time will tell—be more accurate that human research. However, a working system of unique individual identifier would vastly, in my opinion, improve this process.

2. Health plans and health care providers already have systems for identifying subscribers and patients. How can we improve upon the identifiers for individuals there are used in health care today?

Identifiers that range from internally generated numbers, to SSN # are used today. Each has their own potential problem. The causes for these problems lie in the variety of the various systems, the individuals ability to know (i.e. remember) their ID# and the lack of a central source of truth that can be used to find and/or verify known patient demographic information to a patient identifier.

3. What are the viable alternatives to a unique individual identifier?

The next best alternative would be a limited number of managed identifiers (i.e. those with a trusted and available database). Without this, I believe the ad-hoc method of a health-plan or delivery network internally generated and internally managed identifier (i.e. what we have today) is the next most workable that I have given any thought. However, it does not give any relief to external organizations (i.e. other health plans, health providers, or the government).

4. What impacts would a unique identifier for health care have on an individual’s right to privacy?

Without the identifier, it is hard to imagine how we are going to make significant improvements in the use of information systems to handle patient administrative and clinical information. Admittedly, this may make it easier for an individual’s private information to be released. This doesn’t make the release of an individual’s private information any more right or wrong, it may make it easier.

5. How should the Federal Government be involved?

The Federal Government should be involved if a unique identifier is to be used. There needs to be a single source of truth that connects and identifier to a person. If this was to be done by a private concern, then the Federal Government would, at the very least, be the largest single payer and the largest single user of the unique identifier. Someone would have to license or appoint some authority to implement the unique identifier.

Relevant other Questions:

General Questions:

1. The law requires the Secretary to adopt a unique identifier for individuals in health care. What are the most important reasons for having such an identifier?

To correctly identify an individual. Most important...the opportunity to put more and more patient clinical information into computers makes more and more information available on shorter notice to care givers. If the patient is incorrectly identified, the probability for serious clinical errors based on what proves to be incorrect information about a patient’s clinical history and current treatments goes up dramatically.

2. If you are opposed to the adoption of an identifier for individuals for health care, what alternative(s) should the Secretary consider?

Not opposed.

3. Which identifier option do you prefer and which ones should be eliminated from consideration? Why? Are there other identifier options that should be considered?

First of all, and most important, I favor any scheme that provides a unique identifier that meets the need of the health care industry. I would personally prefer that SSN# be use. As imperfect as it may be in its current state, it is an identifier that is already distributed to all Americans and could be implemented in the least time. While it is not perfect, it is something that we have now. It does not cover aliens, has a not insignificant error rate, is limited in size, does not have a check-digit scheme...etc. Nevertheless, it is here now and an infrastructure for supporting it already exists in this country. Going beyond this, the Federal Government could create an entirely new identifier that does a much better job of addressing the 30 criteria listed in the Unique Health Identifier for Individuals White Paper. This may be the best technical choice in spite of the fact that it is probably more expensive and will take more time to implement than SSN#

4. Based on your experience, what identifiers for individuals are used currently?

Based on my experience, identifiers that range from: internally generated numbers, to SSN # are used today. Each has their own potential problem. Causes for these problems lie in: the variety of the various systems, the individuals ability to correctly remember their ID# and the lack of a central source of truth that can be used to find and/or verify known patient demographic information to a patient identifier.

5. The White paper outlines several options that do not require a universal, unique number to be assigned to each person. Could any of these be used to fulfill the Secretary’s statutory obligation to choose an identifier? If so, how?

MPIs are in use today and are being improved. MPIs can satisfies an individual organization’s need for person identification. Many payer organizations have also started to use MPIs especially when it is connected to delivery systems that are integrated with the payer organization. We can continue to improve these systems. However, this will not allow for any relief to inter-organizational electronic transfers between providers, payers and the federal and state governments.

Criteria for Evaluation of Candidate Identifiers

11. What five criteria should be given the most weight in evaluating candidate criteria?

  1. Unique
  2. Deployable
  3. Governed
  4. Identifiable
  5. Mergeable

13. Are there other important criteria that should be considered?

The criteria of accessibility and is also very important and one that does not generally exist today.

15. What are the relative advantages of the Social Security Number (or identifiers that rely on the SSN) when compared with other identifier options? What are the disadvantages?

The primary advantage is the existence and wide distribution of SSN. If it was not widely distributed to most Americans, it would have not significant advantage...and in fact significant disadvantage to other proposed schemes.

Implementation and Transition Issues

30 What are the Implications of implementing the electronic transaction standards without a standard identifier for individuals?

The lack of a standard identifier is the status quo. We will continue on with out current organizationally unique id systems. This makes standards for transfer of information utilize a methodology of bi-lateral (i.e. end-to-end) negotiation as to the semantical meaning of the patient identifier field.

32. Would revivification of SSN make identifier options based on the SSN more acceptable.

Yes.

Length of the Identifier

33. What is the optimal length for the identifier?

34. What is the maximum acceptable length for the identifier?

35. What are the relative costs and benefits of the lengths?

Current Information Technology does not place any practical limit on the length of an identifier. The more important, and non-technical, issue is the minimum allowable length—assuming that a shorter identifier is easier for a person to remember and can more easily fit on a small card.