Public comment to HHS regarding the release of Medicare Physician Data
August 24, 2013
A couple of weeks ago, I noted that HHS invited public comment on the proposal to release Medicare Physician Data. If you haven't done so yet, you still have a couple of weeks. Below is the comment that I submitted.
To The Department of Health and Human Services:
I applaud HHS's release of data in machine-readable form. The release of Medicare Physician Data would be the most revolutionary large-scale physician database that I have yet to see. For example, with the release of claim information, a person who needs a rare surgery can finally search to see which providers have performed that surgery before (at least, which providers have done so for Medicare). Closer to home, the pricing information might have gone a long way earlier this year in helping my family figure out which doctors to approach when someone needed to undergo a specific procedure.
In regards to the questions,
1) It would be the prerogative of any insurer (whether public or private) to release claims data unless they specifically bound themselves with confidentiality agreements. Additionally, considering that government employee salaries are public information and that government payments to contractors are generally disclosed, withholding Medicare payment data would be an odd exception. The public benefit of releasing Medicare information is immense. First, the sheer volume of data from the nation's largest payer would give the public tremendous insight into health care practices. Second, the release of this data creates a powerful example for private insurers to emulate: empowering their customers with useful information when selecting a provider. Any privacy concerns must be weighed against this potential of catalyzing the next generation of tools that could transform the health care industry.
2) CMS should be as open as possible and release as much information as it legally can without encroaching on patient privacy. To add limitations is to limit the innovative uses of this data. Even seemingly unimportant details such as dates of claims can be used to help the public understand when certain conditions tend to occur, or to help provider institutions better allocate their resources on a seasonal basis. Physicians can also use procedure volume information to make more informed referrals.
3) CMS should release the data in as detailed form as possible (e.g. line item claim details). The data should identify physicians by their National Provider Identifiers, include the date of the procedure, the procedure name and code, the condition for which the procedure was prescribed, and the address where the procedure was performed. Presenting claim-level data is important because it would be helpful, for example, to know which procedures are being applied to which conditions. Observing such relationships can be instrumental in detecting fraud, but presenting the data in aggregate form would obscure such relationships. Researchers and others can aggregate data themselves; they cannot reverse the process, so only releasing aggregate data will limit innovation. Patient privacy can be protected by combining records for specific procedures into one line when there are less than five occurrences for a provider in a given year. It would be helpful for the data to be catalogued by individual calendar years or quarters for ease of downloading.
Although not an immediate priority, it would be helpful for CMS to automatically translate CPT codes to codes from an open code set (e.g. SNOMED). After all, one of the same organizations that lobbied so hard to keep this information private owns the CPT code set and might come up with creative ways of restricting usage of the data.
I am encouraged by the increasing availability of physician information over the last few years, and the release of Medicare Physician Data will greatly advance transparency in health care. Empowered by better information, patients will be able to take the next step in making decisions for a higher-quality and more efficient health care marketplace.
In anticipation of a brighter health care future,
Jerry Lin