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National Intelligence Report

Q&As on NPI Contingency Plan for Medicare Fee-for-Service
May 21, 2007

Sidebar: NPI Compliance at a Glance

General Contingency Policy

Applies to healthcare providers and other entities covered under HIPAA (the Health Insurance Portability & Accountability Act), including health plans and health information clearinghouses, that cannot meet the May 23, 2007 deadline. They have up to an additional 12 months to become compliant as long as they are making a good-faith effort to do so.

As of May 23, 2008, only NPIs will be recognized in HIPAA standard electronic transactions.

Medicare Fee-for-Service Policy

CMS will take a flexible approach in enforcing FFS policy regarding NPI compliance, saying it wants to minimize disruptions. No penalties for non-compliance will be imposed, as long as the entity is working toward being able to accept and send NPIs.

• For some period after May 23, 2007, Medicare FFS will:

— Allow continued use of legacy numbers on transactions;

— Accept transactions with only NPIs; and

— Accept transactions with both legacy numbers and NPIs.

• After May 23, 2008, legacy numbers will not be permitted on any inbound or outbound transactions.

Medicare could begin requiring NPI use by primary providers on July 1, 2007 or soon after. The date depends on an assessment of claims submitted with NPIs for these providers.

   

 

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