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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