Prepare for upcoming NPI implementation deadline
The AMA continues to advocate to the Centers for Medicare & Medicaid Services (CMS) on several fronts regarding the implementation of the National Provider Identifier (NPI). The AMA is concerned about Medicare's ability to correctly match physicians' old, or legacy, provider numbers to their new NPI numbers in their systems—and about the requirement for physicians to re-enroll in Medicare if a match can not be made. The Medicare enrollment process for physicians is burdensome and lengthy and the AMA continues to advocate that CMS streamline it.
CMS recently announced a key deadline for NPI implementation:
• May 23, 2008—This deadline applies to all public and commercial claims. Physicians will be required to use only their NPI on all electronic claims. Physicians who bill Medicare on paper must also use only their NPI starting on this date. No legacy numbers will be permitted on claims after this date.
The AMA strongly urges physicians and their office staff members to take the following steps:
1) Look for NPI informational warnings. Since Oct. 15, Medicare has been issuing informational warnings on pre-pass reject reports (M389, M390, M391, and or M392) to billers if no NPI was included on the claim. If you have received one of these messages even though you submitted claims bearing your NPI, it is possible a billing agent or clearinghouse removed the NPI before sending the claim to Medicare. Call your clearinghouse or billing agent to determine how to fix future claims.
2) Begin using your NPI immediately—begin first by sending a few claims through to ensure they process correctly. Doing so now allows time to correct any problems Medicare may encounter when matching your legacy number to your NPI. If these first few claims are rejected, first validate your NPI information in the NPI system. Visit the Web site or call (800) 465–3203 to access the system. Once there, ensure that the correct legacy number appears in the "Other Provider Identification Numbers" field. If the information in the NPI system is correct, contact your contractor and ask they validate what appears in their system.
Social Security Numbers (SSNs) Should Not Be Reported in FOIA-disclosable NPPES Fields
As CMS has mentioned in previous outreach messages and on the CMS NPI website, some health care providers have reported their Social Security Numbers (SSNs), or the SSNs of other health care providers, in their NPPES records in fields that the Freedom of Information Act (FOIA) requires that CMS make publicly available. For example, there are instances where SSNs are reported in the “Other Provider Identification Numbers,” “License Number,” and “Employer Identification Number (EIN)” fields in providers’ NPPES records. The information that providers report in these (and certain other) fields is fully disclosable by CMS to the public and, therefore, SSNs should never be reported in any of these fields.
Because SSNs are 9-digit numbers, CMS has been suppressing all 9-digit numbers found in any FOIA-disclosable field except for ZIP code and telephone/fax number fields. This means that these 9-digit numbers—whether or not they are SSNs--are not displayed in the NPI Registry and cannot be found in the monthly NPPES downloadable file. If these 9-digit numbers are legitimate EINs, “Other Provider Identification Numbers,” or “License Numbers,” health plans and others who are using the NPI Registry and the downloadable file are not able to see them, which means that they cannot see all of the NPPES data they may need in order to accurately match providers in NPPES to the providers in their own files, thus making it more difficult to link NPIs to legacy identifiers. In some cases, this may adversely affect payments to providers by health plans.
It is imperative that providers immediately look at their NPPES records to ensure that they did not inadvertently report their, or someone else’s, SSN in a FOIA-disclosable field; if they did, they need to delete that SSN immediately and, if appropriate, replace it with the correct information (e.g., an EIN). Providers must look in their NPPES records in order to view all of the information they reported. If they need assistance in deleting inappropriately reported SSNs, they may contact the NPI Enumerator at 1-800-465-3203. If they need assistance in knowing which NPPES fields are disclosable under FOIA, they should review the document entitled, “National Plan and Provider Enumeration System (NPPES) Data Elements Data Dissemination – Information for Providers,” dated June 20, 2007, and found on the CMS NPI web page.
Providers cannot rely on the information disclosed in the NPI Registry or in the downloadable file in trying to determine if they inappropriately reported SSNs in FOIA-disclosable fields because CMS suppresses these numbers, as explained above; these numbers will not be seen in the NPI Registry or the downloadable file.
In order to protect your personal information from public disclosure, please correct this information immediately if this situation pertains to you.
The Health Insurance Portability and Accountability Act of 1996 (HIPAA) mandated that the Secretary of Health and Human Services adopt a standard unique health identifier for health care providers. On Jan. 23, 2004, the Secretary published a Final Rule that adopted the National Provider Identifier (NPI) as this identifier.
All HIPAA-covered healthcare providers, whether they are individuals or organizations, must obtain an NPI for use to identify themselves in HIPAA standard transactions. Once enumerated, a provider's NPI will not change. The NPI remains with the provider regardless of job or location changes.
The NPI is a 10-digit identifier that does not carry information about the health care provider, such as the state in which they practice, their provider type or speciality).
Need more information?
Not sure what an NPI is and how you can get it, share it and use it? As always, more information and education on the NPI can be found on the CMS website. Go to: www.cms.hhs.gov/NationalProvIdentStand.
Health care providers may obtain their NPI by requesting a paper application by calling the NPI Enumerator at (800) 465-3203, or applying for a bulk enumeration, which allows an Electronic File Interchange Organization (EFIO) approved by CMS to obtain a number of providers' NPI.
CMS POSTPONES DATE FOR MAKING NPI INFORMATION AVAILABLE TO THE PUBLIC
The deadline for physicians to remove “optional” information has been extended until July 16.
CMS officials have announced a delay in their plan to make NPI numbers and associated information available to the public. CMS originally planned on making the online NPI registry available at the end of June. However, because of aggressive AMA advocacy, CMS is postponing making the NPI registry available until Aug. 1. In the meantime, physicians have until July 16 to verify the accuracy of information and delete any information in the “optional” category that a physician does not want to share with the public. A list of “optional” information is available at http://www.cms.hhs.gov/NationalProvIdentStand/06a_DataDissemination.asp#TopOfPage (look under downloads).
CMS establishes contingency plan for NPI implementation
Begin testing NPI immediately
Effective May 23, 2007, Medicare fee for service (FFS) established a contingency plan for implementing the National Provider Identifier (NPI). In May 2007, Medicare FFS will evaluate the number of submitted claims containing a NPI. If this analysis demonstrates a sufficient number of submitted claims contain a NPI, Medicare will begin to reject claims without NPIs on July 1, 2007. If, however, there are not sufficient claims containing NPIs in the May analysis, Medicare FFS will assess compliance in June 2007 and determine whether to begin rejecting claims in August 2007.
CMS announced that through May 23, 2008, penalties will not be imposed on covered entities that deploy contingency plans. To access documents that can be used by covered entities to design and implement a contingency plan go to http://www.cms.hhs.gov/NationalProvIdentStand/
Testing Medicare Claims
For months, Medicare has encouraged providers to submit both an NPI and a legacy identifier on claims. Medicare is now asking that submitters send a small number of claims using only the NPI as a test to determine if everything is set up correctly for the final transition to using only NPI numbers. If no claims are rejected, the submitter should gradually increase the volume. This process will help establish confidence that claims will be paid. It is critical to start testing NPIs now.
New Tip Sheet Available
A Tip sheet entitled What the "Guidance on Compliance with the HIPAA National Provider Identifier (NPI) Rule" Means for Health Care Providers is now available at http://www.cms.hhs.gov/NationalProvIdentStand/Downloads/ContingencyTipSheet.pdf
This product provides helpful steps for providers based on the contingency guidance released on April 2, 2007. This guidance does not mean that providers have an extra year to get an NPI, so please view the Tip Sheet for additional information.
When to Contact the NPI Enumerator for Assistance
Providers should remember that the NPI Enumerator can only answer/address the following types of questions/issues: [Amanda, change the asterisks to bullets]
* Status of an NPI application, update, or deactivation
* Forgotten/lost NPI
* Lost NPI notification letter
* Trouble accessing NPPES
* Forgotten password/User ID
* Need to request a paper application
* Need clarification on information that is to be supplied in the NPI application
Providers needing this type of assistance may contact the enumerator at (800) 465-3203, TTY (800) 692-2326, or e-mail the request to the NPI Enumerator atCustomerService@NPIenumerator.com.
The Centers for Medicare and Medicaid Services (CMS) along with the Workgroup for Electronic Data Interchange (WEDI) and other industry health plans would like to remind providers of the following key NPI facts:
• Every covered health care provider must get and use the NPI; and even if a health care provider is an individual and is not conducting electronic transactions and is, therefore, not a covered provider, he or she may be required by health plans or employers to obtain an NPI.
• The NPI will affect internal and external business and systems operations and can affect the appropriate payment of claims in a timely manner.
• Use of the NPI can require a transition period of no less than 120 days.
• A health care provider who is a sole proprietor is considered an individual and can only have one NPI.
Once providers have received their NPIs, they must share it with other providers, health plans, clearinghouses, and any entity that may need it for billing purposes - including designation of an ordering or referring physician. Providers should also consider letting health plans, or institutions for whom they work, share their numbers for them.
Resources for Commonly Asked Questions
Additionally, CMS continues to build its database of Frequently Asked
Questions (FAQs) on NPI. Recently, an FAQ on Electronic File Transfer
(EFT) of payments from health plans to health care providers was added,
All Questions can be viewed at http://questions.cms.hhs.gov