MINC # NIMC - Program Description

A Medical Identification Number for Canada (MINC) system has been developed to identify every individual in the Canadian medical education and practice systems. MINC numbers will be issued by MINC#NIMC (the “hub” organization), which has been incorporated by the FMRAC and the MCC.

MINC numbers will be issued to all individuals at the time of first (even temporary) entry to any aspect of the Canadian medical education or practice systems, including undergraduate students, postgraduate trainees, applicants to MCC examinations, and physicians of any registration status.

Once assigned, MINC numbers remain unchanged throughout the individual’s entire medical career. Assigned numbers are never re-used, even after the death of the individual. Individuals carry the same MINC, even if they leave Canada and return, move between jurisdictions, or change registration status.

No information is encoded in MINC numbers (other than country and profession assigning the number), and they will reflect no special privilege, rights or status. They are simply serial numbers for identification purposes.

All medical regulatory authorities in Canada have endorsed the MINC as a primary means of identifying individuals whom they register; the MCC will also use MINC numbers to identify all individuals whom they may register to write their exams. Other organizations which maintain databases of physicians or physician information will be encouraged to become Licensed Users of the MINC system as well.

The CSA Model Code for the Protection of Personal Information (also reflected in PIPEDA, the federal privacy legislation) will guide the operation of the MINC system. Licensing agreements will bind such users to implement CSA principles within their organizations.

As privacy and operational issues are still being developed, aspects of this program description or implementation are subject to change.

All organizations which maintain databases of physician information currently have an identifier (typically numeric) for each physician. Depending on the organization, this could be a registration number, a billing number, a member number, or some other unique identifier.

For a number of years, the idea of having a national system of unique physician identifiers for all physicians in Canada has been considered by a variety of organizations. A number of these organizations have instituted such identification numbering systems, but none have been adopted for shared use on an inter-provincial or national basis.

Difficulties do arise when trying to confirm the identity of physicians between such databases. For example:

- to confirm that the individual seeking registration in Alberta is not the same person who was disciplined by the College of Physicians and Surgeons of Ontario,

- to determine how many physicians have active licenses in more than one province or territory.

- to track where physicians enter practice after completing their training at Memorial University

- to provide to regulatory authorities lists of individuals who have received degrees, licensure, certification or other credentials.

Without common identifiers, such tasks are tedious at best; inaccurate or impossible at worst. Even when surnames are used, first names, addresses and/or other secondary identifiers are needed to match the files. Thus, the reliable identification of individuals is frustrated, and the chance of error increases.

In November 1996, a Technical Working Group of the Canadian Medical Forum met, and developed an excellent report with recommendations for the establishment of Medical Identification Number for Canada (MINC).

Working from that base, the Federation of Medical Regulatory Authorities of Canada (FMRAC) and the Medical Council of Canada (MCC) developed a mechanism to establish and maintain the MINC numbering system.

MINC numbers establish a reliable, verifiable identifier for all physicians, and provide a common thread which would enable organizations which have been licensed for their use to link their databases (or selected aspects of them) for approved regulatory, administrative or research purposes.

All of the medical regulatory authorities in Canada have endorsed the establishment of the MINC system. They recognize the value to their regulatory function of being able to confirm the identity and history of individuals applying for registration in their jurisdictions. It is expected that, once the MINC system is fully operational, every medical regulatory authority will require applicants to provide (or be provided with) a MINC number as part of their registration process.

In developing a national unique identifier, it is acknowledged that one of the threats to the privacy of physicians so identified could be the use of that identifier for unintended purposes (“function creep”). The FMRAC and MCC are sensitive to that possibility, but believe that the privacy provisions built into the MINC system (see privacy policy) will safeguard against it.

It is also recognized that the privacy risks of developing a system for creating such numbers are distinct from the ongoing risks associated with using such a numbering system. Again, the FMRAC and MCC believe that the safeguards built into the MINC system mitigate such risks, and that the benefits of such a system, including increased accountability and general improvements in information handling, will outweigh these potential risks.

A not-for-profit corporation, MINC#NIMC, has been incorporated to operate the MINC system. Two organizations, the Federation of Medical Regulatory Authorities of Canada (FMRAC) and the Medical Council of Canada (MCC) are the sole members of MINC#NIMC.

The FMRAC is a federally-incorporated body whose members include all of the medical licensing authorities in Canada. Its purpose is to “provide[s] a national structure for the provincial and territorial medical licensing authorities to present and pursue matters of common concern and interest, and to share, consider and develop positions on such matters”.

The MCC was constituted in 1912 by the Canada Medical Act. Its purposes were reconfirmed in 1976, and include:

a) “to establish and promote a qualification in Medicine, known as the Licentiate of the Medical Council of Canada (LMCC)…”

b) “to establish and maintain a register to be known as the Canadian Medical Register, on which shall be recorded the particulars of physicians who have fulfilled the requirements of the Licentiate.”

a) to develop and maintain a system which will provide a national unique lifetime identifier for every individual who enters the Canadian medical education or practice systems,

b) to safeguard the personal information which is gathered to verify the identity of such individuals, and

c) to authorize the use of the MINC number system for non-commercial administrative or research applications.

MINC#NIMC will establish an Advisory Forum, composed of members invited from a variety of national medical stakeholder groups. This Forum’s role will be to provide policy advice for the operation of the MINC system. While MINC#NIMC will not be legally accountable to this Advisory Forum, its assistance and recommendations are intended to provide a mechanism for feedback and accountability in the operation of the MINC system.

A MINC number will be generated to identify every individual who enters the Canadian medical education or practice system:

Graduates of international medical schools will be assigned a MINC number at the time of application to any of the above agencies. All individuals already in the national medical system - students, residents, fellows, physicians holding any type of medical license in any province or territory (even a temporary license) – will also be issued a MINC.

The MINC number does not convey any status, rights or privileges. Numbers will never be deleted or re-used; they have no time limitation. Once an individual is assigned a MINC number, they would keep it, unchanged, regardless of their location, registration status or activity.

The Medical Identification Number for Canada (MINC) is a 12-character identifier composed of:

a) A two-letter country code, indicating the country which issued the MINC identifier. For Canada, this identifier will be CA.

b) A two-letter profession code, indicating the professional body which issued the number. For physicians, this code will be MD.

c) seven numeric digits, which are simply a serial number, with no encoded information, and

d) a final check digit, generated by a mathematical formula of the other digits, to guard against transposition errors.

where “9” is the check digit. This formula allows for ten million individuals per profession per country to have unique numbers.

The MINC identifier does not incorporate or codify any information (aside from country and profession); it is simply a serial number.

MINC numbers would not replace the registration numbers assigned by the various licensing authorities. Nor would MINC numbers replace the LMCC number, RCPSC or CCFP number, physicians’ billing numbers, or any other current identification number. These other numbers reflect legal status, certification or other authority; the MINC number’s only purpose is to confirm the identity of the individual.

MINC numbers are considered to be confidential personal information, and will be protected as such.

MINC#NIMC will maintain the hub computer database which will issue and manage all MINC numbers, on behalf of the Prime Users. The hub will exist independently of any other physician database, and will contain only the data elements listed below. Strict confidentiality rules will govern the operation of the MINC system (see Privacy Policy).

MINC Prime Users (all 13 medical regulatory authorities, plus the MCC) will submit the names and core information to this hub. They will be able to inquire if a MINC number already exists for an individual, or to request issuance of one.

The only information that the MINC#NIMC hub will gather and retain is that which permits validation that a MINC is being assigned to an individual who does not yet have one, or to confirm the identity of MINC number holders.

The following core data elements will be required to be submitted to the MINC#NIMC hub in order for a MINC to be issued (or confirm that a MINC has already been issued). These data elements were chosen because they are (except for name) unchangeable, and all will have source documents by which the information could be verified.

5) institution issuing medical degree (if applicable; see Note 3, below.)

6) year of medical degree (if applicable; see Note 3, below)

8) additional identifiers (optional) (standardized and coded, e.g., medical students would have their medical school and expected year of graduation recorded here.)

1. Where provincial privacy or other such statutes prevent the release of certain of these core data elements to the MINC hub, Prime Users would provide whichever of the core elements they can.

2. The “country of birth” has been included only because it presents another unique, documentable identifier.

3. For medical students, the institution and year of medical degree fields should be left blank. In this case, a note would be added to the “additional identifiers” field, noting the expected institution and year of graduation.

When the MINC is generated the hub will automatically add that number, the identity of the submitting Prime User, the Prime User’s registration or file number, and the submission date to the individual’s file.

All inquiries/requests will require submission of all of the above core information. If a MINC number already exists for the individual, that number would be provided back to the submitting organization. If a number has not yet been issued, one would be generated, the computer file updated, and the new number sent out.

The only updating to the MINC database which should be necessary would be a legal change of name after issuance of the MINC, or correction of core information later found to be erroneous. Since the purpose of the MINC hub is to manage the issuance of numbers, it is unnecessary to keep track of changes of address, qualifications, registration status, or even death of the practitioner. Files would not be removed from the database.

Core information is collected and retained for the sole purpose of verifying the identity of the individual; there is no issue of eligibility to be determined.

Further operational details are outlined in Prime Users and Licensed Users.

Other organizations will be licensed to use the MINC numbers, based on a contractual agreement. Licensed Users would have to agree:

a) to be provided MINC numbers for physicians, and would be permitted to make inquiries of the MINC database, but would not be Licensed to add to or amend said database;

b) to be bound by a confidentiality agreement for their organization, based upon the CSA Model Code;

c) not to use MINC numbers except for internal identification purposes, i.e., could not use MINCs as registration, membership, billing or other numbers;

d) not copy, give, sell or allow MINCs to be used by any other person or organization;

e) to assume full responsibility for their employees, contractors and agents to comply fully with the terms of this agreement, even beyond the time of the working arrangement;

f) to abide by the COACH guidelines for confidentiality and security, and to undergo audits of their information-handling practices if demanded by MINC#NIMC;

g) not to use MINC numbers as the basis for any other identification system, unless the numbers were securely encrypted;

h) to apply MINCs only to uses approved by MINC#NIMC, which would be appended to and form part of their agreement;

i) to use MINCs as the basis for exchanging physician information only with other Licensed and Prime Users;

j) that default on any of the conditions of the licensing agreement will result in the loss of access to future MINC updates, and would no longer be entitled to use MINC numbers as a means of exchanging information with other Licensed Users.

k) to continue to be bound by the obligations of this agreement, excluding clause (j), irrevocably, and this obligation shall extend to any successor owners and/or directors of this organization.

An expected secondary benefit of the MINC system is to expand awareness of, and attention to, issues of confidentiality and fair information handling.

Testing and first implementation has been completed in four provinces to date; rollout to other medical regulatory authorities (“Prime Users”) is currently under way.

The Privacy Commissioners of each of the provinces, as well as the Federal Privacy Commissioner, have been polled as to privacy concerns with the operation of the MINC system that have not already been addressed. Their input has been vital in the development of a system in which all stakeholders have confidence.

Once all of the Prime Users have been equipped to deal with the issuance of MINC numbers, and numbers assigned to all individuals currently within the Canadian medical education and practice systems, the next stage will be to license the usage of MINC numbers by other agencies. A detailed review of these users’ requirements will be part of this stage.

As described above, only Prime Users and Licensed Users would have access to MINC numbers. The goal will be to establish MINC numbers as the primary national identifier for all databases in Canada which maintain physician information.