May 7, 2007
The 23rd of this month remains the final deadline for HIPAA-covered entities (other than small health plans) to comply with National Provider Identifier (NPI) requirements, the Centers for Medicare & Medicaid Services emphasizes.
But while CMS gave entities that cannot meet the deadline up to 12 more months to become compliant, it plans to accelerate the move to required NPI use on Medicare fee-for-service (FFS) claims from certain providers, perhaps as early as July 1, 2007.
General Policy on NPI Contingency Plans
Citing a lack of industry-wide readiness to conduct NPI-only HIPAA standard electronic transactions, CMS says it will enforce NPI compliance flexibly to assure a smooth transition and minimize cash flow disruptions. Covered entities—health plans, healthcare providers, and health information clearinghouses—have until May 23, 2008, to become compliant. They may establish contingency plans to facilitate NPI implementation with their trading partners. No penalties for non-compliance will be imposed and claims will continue to be paid, as long as they are making a good-faith effort to become compliant, "meaning working toward being able to accept and send NPIs," CMS said.
It is up to each covered entity to determine its own contingency plan. Medicaid programs in California and four other states have already announced delays in their NPI transition. Anthem Blue Cross and Blue Shield says it aims to complete the switch in early 2008, and Aetna says it will accept legacy identifiers until May 23, 2008.
Medicare FFS Contingency Plan
When it comes to Medicare, labs and other providers shouldn’t be complacent. In recently released contingency guidance, CMS lays out its NPI policy for FFS providers (CMS Change Request 5955, April 24, 2007):
• 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.
As soon as the number of claims submitted with an NPI for primary providers is sufficient, Medicare will begin rejecting claims without an NPI for these providers following advance notice. If the number of claims is sufficient in May, the start date for rejections will be July 1, 2007. If the number is insufficient, CMS will look again in June and decide whether to start rejecting claims in August 2007.
Primary providers are defined as billing, pay-to, and rendering providers. All other providers are defined as secondary—they include "referring, ordering, supervising, facility, care plan oversight, purchase service, attending, operating, and ‘other’ providers," says CMS. Legacy numbers are acceptable for secondary providers until May 23, 2008. If a secondary provider’s NPI is on a claim, it will only be edited to assure that it has 10 digits, that it begins with "1," "2," "3," or "4," and that the 10th position of the number is a correct check digit.
Industry Challenges
For labs and other providers, the core challenge is how you interact with your trading partners, emphasized the two speakers featured in the April 30 NPI compliance audio conference sponsored by Washington G-2 Reports/IOMA. Your compliance will depend on theirs, and they are likely to be at different stages of preparedness and to have differing contingency timetables.
When getting in synch with their trading partners, labs should recognize that time will be needed to get full NPI enumeration and test software, but labs should also be sure there is a mutually agreed-upon date for achieving compliance, said LabCorp associate vice president Kimberly Williams during the audio conference.
Getting in synch is a big job, Williams said. For example, you could have 200,000 relationships, and right now that would mean 200,000 requests. What the industry needs sooner rather than later is a single-source repository for accessing NPIs and crosswalks to legacy identifiers, she said. This is vital in preventing payment disruptions since claims will require the number of both the primary billing provider and the ordering or referring provider. CMS is scheduled to issue guidance in this area this month, according to the HHS semiannual regulatory agenda, Williams said. At press time, the notice was not yet published, though CMS officials have said it is expected out shortly.
The transition to sole NPI use can be a complex chore, but it also is a new paradigm for doing business and simplifying administrative procedures, Williams observed. Providers will own their identifiers; payers will no longer assign them. Providers will identify themselves in all standard transactions with one set of identifiers. Providers will request and receive payment on all claims to existing and future payers with one set of identifiers.
Lâle White, executive chairman & CEO, Xifin, Inc. (San Diego, CA), advised the audio conference audience to act immediately to get an NPI and begin collecting and testing NPIs from trading partners. To demonstrate good-faith and avoid penalties, you need to show that you have already obtained and started using NPIs in HIPAA standard transactions, she said. CMS is likely to be strict on this point, since it began issuing NPIs in May 2005, giving providers two years to get and start using them.
Resources
- To apply for an NPI, go to the National Plan/Provider Enumeration System (NPPES) Web site at https://nppes.cms.hhs.gov .
- For updates on NPI policy, go to www.cms.hhs.gov/NationalProvidentStand.
- Recordings of the April 30 G-2 audio conference NPI Countdown To Compliance: Are You Ready? may be purchased for $219 ($199 for G-2 subscribers). To order, go to www.g2reports.com and click on "Recordings."
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May 7, 2007 - Table of Contents
