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Spring 2024 Issue

What’s in a Name?
By Selena Chavis
For The Record
Vol. 36 No. 2 P. 22

Stakeholders weigh in on new AHIMA naming policy framework for patient identity management.

The quest for a national patient identification system goes all the way back to the introduction of HIPAA in 1996. Yet decades later, the health care industry is still no closer to achieving the original goals laid out, as detailed by an op-ed that appeared in the HIPAA Journal last year.1

And while the public-private debate continues over where ownership of a patient identification standard should live, the industry at large recognizes there is much at stake when it comes to accurate patient matching and safety. The shortfalls of patient mismatching and inaccuracies are well established in the industry and can lead to information gaps in patient records, repeated testing, delayed care, and unnecessary costs. Notably, one recent study conducted by Patient ID Now revealed organizations are spending 110 hours per week resolving patient identity issues, and one-third are spending $1 million annually on patient matching.2

In recent years, multiple private efforts have sought to improve the outlook by establishing standards for patient matching. In one of the more recent efforts, AHIMA updated and launched its Naming Policy Framework 2023: Enhancing Person Matching With Essential Demographic Data Elements last year to help capture standardized data and assist in identifying patients in health IT systems.3

A naming policy, in essence, is intended to provide an organizational structure for data entry and collection of essential data elements across networks. According to AHIMA, the standardized framework serves as a “rising floor” that will evolve over time with advances in technology and operational procedures to ensure it remains relevant and effective.

Introduction of the framework is a critical step forward, according to Stephen Young, RHIA, MBA, MSIS, director of records management and information governance at AmeriHealth Caritas and part of the development panel for AHIMA’s latest naming policy framework, but the real hurdle is getting it adopted and mainstreamed. “The challenge for AHIMA is just brand recognition and getting their voice out there,” he says. “There needs to be a larger understanding and acceptance of who AHIMA is and why it’s coming forward with this framework. And it has to reach the C-suite; otherwise, it’s not going to get much movement.”

Rachel Podczervinski, MS, RHIA, vice president of professional services at Harris Data Integrity Solutions and another member of the development panel, agrees, noting that “my aspiration for the Naming Policy Framework is its widespread adoption by health care systems, both within the United States and internationally. The ultimate goal is to establish a universal policy across all health care systems, ensuring that data entry follows a standardized format and adheres to a common set of rules.”

Erin Head, MBA, RHIA, CHDA, CCS, CHTS, a senior health care consultant at Iron Mountain and also a framework panel member, believes use of the naming framework will establish a more efficient, accurate, and patient-centric health care system. “Through improved patient identification, streamlined registration practices, and the implementation of a true enterprise master patient index (EMPI), health care organizations can elevate the quality of care, enhance operational efficiency, and ultimately contribute to better patient outcomes,” she emphasizes. “Health care leaders can leverage the EMPI to obtain a holistic view of a patient’s medical history, treatments, and ongoing care plans, thereby enabling more informed decision-making.”

How We Got Here
The lack of significant progress on the national stage can be attributed, in part, to ongoing resistance in the US House of Representatives, Podczervinski says, adding that while the concept was part of the original HIPAA law, Section 510 has been included in House appropriations bills annually since the enactment of HIPAA. Essentially, Section 510 creates a roadblock by restricting the use of funds to promulgate or adopt any final standard related to a unique health identifier for an individual, unless specific legislation approving the standard is enacted.

“This section explicitly prohibits any organization from exploring or adopting a national patient identifier,” she explains. “AHIMA and the Patient ID Now Coalition have diligently advocated for the repeal of Section 510, facing resistance in Congress.”

The federal government remains hesitant to assign or mandate a single patient identifier, Young suggests, pointing to security infrastructure shortfalls as a primary concern. He notes that the backdrop to this reticence resides with fears that it becomes easier for a malicious actor to get hold of a single identifier that passed from institution to institution.

For this reason and more, health care organizations are reticent to embrace just any industry standard. “With a lack of government mandate, it comes down to resource, trust, and who’s putting it out there,” Young explains. “Who is the voice of authority? And then security.”

Head points out that standardizing patient identification faces challenges due to insufficient interoperability among systems, which is exacerbated by proprietary settings and configurations in various applications. “This obstacle hinders progress in promoting crucial standardizations for improving patient care and data integrity,” she notes. “Overcoming these challenges is imperative to establish a seamless health care ecosystem that places accurate patient identification at the forefront and promotes interoperability across a range of platforms.”

Highlights of the New Framework
AHIMA initiated the creation of the Naming Policy Framework in response to expressed needs from its membership for comprehensive guidance on patient naming and related standards. The organization has called for the adoption of this demographic data element framework, representing current operational best practices that are designed to evolve over time with technological advancements and operational procedures to ensure relevance with the dynamic nature of health care.

The framework report details the following three key focus areas of the Naming Policy Framework3:

• Standardizing Naming Policies: This addresses the lack of standardization in naming policies across the health care ecosystem. This standardization is crucial for efficient and accurate identification and matching of person(s) to their health records, as well as for large data set migrations.

• Recognizing Evolving Ecosystem: The framework acknowledges the changing landscape of HIM, where essential person(s) demographic data goes beyond traditional master/enterprise patient indexes. With entities collecting and sharing electronic health information, additional data elements become necessary for effective identification, matching, and management of health records.

• Guiding Best Practices: AHIMA calls for the adoption and use of this demographic data element framework, representing current operational best practices. It is designed to evolve over time with technological advancements and operational procedures, ensuring it remains relevant and effective in the ever-changing health care environment. AHIMA initiated the Naming Policy Framework in response to the expressed needs of its membership for comprehensive guidance on patient naming and related standards.

Podczervinski’s deep experience with patient matching and involvement with such initiatives as Project US@—a program focused on the capture of patient addresses—landed her an invitation to the panel. While she believes the entire document is essential, Podczervinski calls out specific areas of importance such as those that address challenging naming situations—particularly the sections focusing on cultural naming conventions, newborn naming, preferred names, and patients with a single legal name.

“These aspects delve into complexities that often arise in real-world scenarios, providing crucial guidance on navigating these challenges,” she says. “By addressing these specific naming situations, AHIMA’s framework ensures a more comprehensive and practical approach, making it a valuable resource for health care professionals dealing with diverse patient demographics.”

Young, whose expertise from both the payer and provider side of health care helped bridge stakeholder gaps on the panel, notes that an important distinction the panel made was to move away from the term “patient-centric” to “person-centric,” which helps move the discussion outside the walls of a hospital or provider organization to be more inclusive of the industry as a whole. For example, payers use the term members as opposed to patients.

In addition, Young points out that the naming framework is also much more inclusive of modern society in general by providing an accounting for gender and other ID preferences as well as cultural and religious nuances. “It equips users to more accurately capture someone’s name in two ways: 1) to make sure it’s accurate and captured in a way that meets legal guidelines for those types of operations and to ensure matching of information across entities and clinical workflow, but 2) also to manage it in a manner that respects the patient or person,” he explains. “Why is that so important? If we don’t show that we’re respecting your identity, your culture, then there’s going to be a lack of trust from the start, and thus, a lack of trust in sharing information that’s imperative to the clinical aspect or health of that person.”

Mainstreaming the Framework
In an August 2023 Journal of AHIMA article, authors Lesley Kadlec, MA, RHIA, CHDA, director of knowledge and practice for AHIMA, and Julie A. Pursley, MSHI, RHIA, CHDA, FAHIMA, senior director of knowledge and practice at AHIMA, note that “AHIMA is urging all health information professionals to adopt the AHIMA Naming Policy and, where appropriate, to compare the components of the 2023 AHIMA Naming Policy Framework to any existing organizational naming policies that outline how person demographics are being collected in health IT systems.”

They also point to the section on patient demographics/information in Version 4 of the United States Core Data for Interoperability,4 recommending that those data elements used to categorize individuals for identification, records matching, and other purposes be incorporated into an organization’s naming policy to ensure alignment with those data standards.

While adoption of the Naming Policy Framework is top-of-mind for all contributing parties, experts acknowledge there are challenges. From a broad perspective, Podczervinski notes that foundationally, it’s a heavy lift for organizations to adjust existing policies to align with the framework.

“Change, especially in established policies, can be inherently challenging,” she says. “Furthermore, each organization encounters unique hurdles based on the diverse makeup of their patient populations. Some entities may find it more challenging to incorporate certain elements of the framework due to compatibility issues with existing technology or specific characteristics of their patient demographics.”

Young believes that awareness is only one step forward and that AHIMA will need to walk their members through the process of getting organizational buy-in. In essence, HIM directors, consultants, privacy officers, and other key AHIMA provider stakeholders will need tools to “sell” the framework to the C-suite. “So empower the membership to do that, create the advocacy, and also AHIMA in general—make those connections to other organizations associations in the industry—the health insurance associations, HMO [health maintenance organization] associations—so they’re aware of this effort and can look to us and know who we are.”

Podczervinski’s acknowledges that not every organization will seamlessly adopt every aspect of the framework. “However, the hope is that organizations will strive to embrace as much of the framework as possible, understanding that even incremental adoption can contribute significantly to the overall goal of standardizing patient data practices across the health care landscape,” she says.

— Selena Chavis is a Florida-based health care writer.


1. Alder S. Editorial: time to stop blocking a national patient identifier system. The HIPAA Journal website. https://www.hipaajournal.com/time-to-stop-blocking-a-national-patient-identifier-system/. Published February 24, 2023.

2. Patient ID Now. New perspectives on the patient ID problem in healthcare. https://patientidnow.org/wp-content/uploads/2022/11/PIDN-Research-Findings-Final.pdf

3. AHIMA unveils naming policy framework 2023: enhancing person matching with essential demographic data elements. AHIMA website. https://ahima.org/landing-pages/ahima-naming-policy/

4. Office of the National Coordinator for Health Information Technology. United States Core Data for Interoperability. Version 4. https://www.healthit.gov/isa/sites/isa/files/2023-10/USCDI-Version-4-October-2023-Errata-Final.pdf. Published October 2023.


In 2018, the Sequoia Project released the results of a multiyear effort that examined and revised its previously released best practices for patient matching between health information exchange partners. The A Framework for Cross-Organizational Patient Identity Management 2018 is described by the organizations as a multidimensional document featuring a matching maturity model, a detailed case study, and specific practices for a national patient matching framework.1

The framework was designed by a Patient Identity Management Workgroup comprising industry, academic, standards, and government experts who dispositioned hundreds of public comments to inform the report’s best practices. Notably, the Sequoia Project published its first framework in 2016 with research partner Intermountain Health Care, which sparked a national dialogue on its efficacy and ultimately the formation of a Patient Identity Framework Work Group.

In tandem with the report, The Sequoia Project also released a case study as a supplement to the framework that documents the journey of Blue Cross and Blue Shield Association (BCBSA) to develop an algorithm with a 99.5% accuracy rate across 36 independent companies.2 Noting that BCBSA represents a microcosm of the health payer ecosystem as a whole, the case study reveals the problems payers typically face in linking health care services provided to an individual over time.

The case study notes that: “The work done by BCBSA in the development of the MMI [master member index] has yielded many positive results and has the ability to enhance patient care outcomes by informing value-based care solutions. The MMI work to date can contribute to the body of knowledge and development of public policy. The foresight of the BCBS System leaders who committed to a strong person matching program will enable the BCBS System to quickly scale the existing MMI solution to meet future regulations around interoperability solutions based on confirmed person matching. Above all else, the efforts to ensure the necessary foundation of interoperability based on accurate person matching, will contribute to a better US health care data infrastructure upon which further interoperability goals will rest.”


1. A framework for cross-organizational patient identity management. The Sequoia Project website. https://sequoiaproject.org/framework-for-cross-organizational-patient-identity-matching/. Updated 2018.

2. Person matching for greater interoperability. The Sequoia Project website. https://sequoiaproject.org/resources/patient-matching/blue-cross-blue-shield-case-study/. Published November 2020.