Public Comments

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September 15, 2026
Via Electronic messaging: [email protected]
Subject: Agency Information Collection Activities: Proposed Collection: Public Comment
Request; Information Collection Request Title: National Practitioner Data Bank for
Adverse Information on Physicians and Other Health Care Practitioners - 45 CFR Part 60
Regulations and Forms, (OMB No. 0906-0081 – Revision), Federal Register Doc. 202614476
Dear Sir/Madam,
Highmark Inc. (Highmark) is one of the nation's largest health insurance organizations and an
independent licensee of the Blue Cross Blue Shield Association, serving millions of members
across Pennsylvania, Delaware, Kansas, Missouri, West Virginia, and New York. Through its
affiliated companies, Highmark offers a broad range of health insurance products and services,
including commercial coverage, Medicare, Medicaid, pharmacy benefits, and care management
programs.
Highmark is committed to improving health outcomes, enhancing the patient experience, and
advancing affordable, high-quality care through innovative approaches to health care delivery
and financing. As a health insurer with a strong focus on patient safety, quality improvement,
provider accountability, and informed consumer decision-making, Highmark has a significant
interest in policies governing the collection, reporting, and use of practitioner quality and
disciplinary information, including the operations of the National Practitioner Data Bank
(NPDB).
Highmark appreciates the opportunity to comment on the Health Resources and Services
Administration's (HRSA) proposed revision to the National Practitioner Data Bank (NPDB)
information collection requirements. We support the overall purpose of the NPDB as a tool to
promote patient safety, support credentialing activities, and prevent practitioners with serious
adverse actions from avoiding accountability by moving across organizations or states.
While we support continuation of the NPDB, we believe there are important limitations in the
current framework that warrant consideration as HRSA evaluates future improvements to the
system.
Limited Access to NPDB Information
The NPDB is primarily designed for use by hospitals, health plans, licensing boards,
credentialing organizations, and other authorized entities. Although practitioners may conduct a
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self-query, patients and members of the general public cannot directly access NPDB information.
As a result, the database functions largely as a professional credentialing and oversight tool
rather than a consumer transparency resource.
This restricted access limits the ability of patients to independently evaluate information that
may be relevant to their health care decisions. While there are legitimate concerns regarding
confidentiality, due process, and the potential for misinterpretation of reports, HRSA should
consider whether additional mechanisms could be developed to provide consumers with
meaningful and understandable information regarding practitioner disciplinary actions and
adverse findings.
Importance of Timeliness
The utility of any provider oversight database depends on the timeliness of the information
available through it. In our experience, other federal transparency initiatives, such as the Centers
for Medicare & Medicaid Services (CMS) Open Payments database, often contain information
that is 18 to 24 months old by the time it is publicly available. Such delays substantially diminish
the value of the information for decision-making purposes.
Although the NPDB serves different purposes than Open Payments, HRSA should continue to
evaluate opportunities to improve the timeliness of reporting and dissemination. Delayed
information limits the usefulness of the database for employers, credentialing organizations,
health plans, and practitioners seeking accurate and current information regarding professional
conduct and disciplinary history.
Patient Safety Considerations
The NPDB serves an important patient safety function by enabling authorized entities to identify
potentially problematic patterns of practitioner behavior and adverse actions. However,
stakeholders have raised concerns the current structure may inadvertently create barriers to
broader quality improvement efforts.
For example, some commentators have argued fear of a permanent adverse report may
discourage open discussion of medical errors and discourage participation in initiatives designed
to learn from mistakes and improve patient safety. Others have noted the database's limited
public accessibility reduces patients' ability to use this information when making health care
decisions. Critics contend restricting public access prevents patients from evaluating potentially
relevant information, while supporters maintain broader disclosure could discourage candid
reporting and undermine the effectiveness of the system.

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These competing policy considerations illustrate the need for HRSA to continue assessing
whether the NPDB strikes the appropriate balance between practitioner accountability, patient
protection, transparency, and a culture of continuous quality improvement.
Future Considerations
As HRSA evaluates future modifications to NPDB operations and reporting requirements,
Highmark encourages the agency to consider:
•

Whether greater patient access to certain categories of practitioner information could
improve informed decision-making while preserving appropriate privacy and due process
protections.

•

Opportunities to improve the timeliness of reporting and data availability.

•

Mechanisms to ensure the NPDB continues to support patient safety and quality
improvement efforts without creating unintended disincentives for transparent error
reporting and organizational learning.

•

Whether additional public-facing educational resources could help patients better
understand practitioner qualifications, disciplinary actions, and the limitations of
available reporting systems.

Conclusion
We appreciate HRSA's continued efforts to maintain the NPDB as an important component of
the nation's health care oversight infrastructure. While the NPDB remains a valuable
credentialing and patient safety resource, improvements related to accessibility, transparency,
and timeliness could further strengthen its effectiveness and utility for both health care
organizations and the public.
Thank you for your consideration of these comments.
Respectfully,

Amy Sawyer
Health Policy Director
Government Affairs
Highmark Inc.
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Pittsburgh, PA 15222-3099
Email: [email protected]
Work 412.544.2455
Cell 860.798.9247

Footnote citations
1. Health Resources and Services Administration, National Practitioner Data Bank
Guidebook, explaining that NPDB information is available only to authorized entities and
that the general public does not have access to NPDB reports. Available at:
https://www.npdb.hrsa.gov.
2. Mello MM, Studdert DM, Brennan TA. "The National Practitioner Data Bank and
Physician Accountability." JAMA. Discussing the NPDB's role in patient safety,
physician accountability, and reporting concerns.
3. Government Accountability Office (GAO), reports concerning physician oversight and
practitioner data reporting systems, discussing strengths and limitations of adverse action
reporting systems.
4. HRSA, National Practitioner Data Bank Guidebook, sections describing the purpose of
the NPDB as a flagging system intended to support credentialing, peer review, and
patient safety activities.
5. CMS Open Payments program documentation describing publication lags associated with
annual submission, review, and publication cycles. (Support for comments regarding the
value of timely transparency data.)

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