CMS REMINDS MEDICARE FEE-FOR-SERVICE PROVIDERS AND SUPPLIERS NPI DEADLINE IS MAY 23
The Centers for Medicare & Medicaid Services (CMS) reminds all Medicare providers and suppliers that beginning May 23, 2008, they are required to use only a National Provider Identifier (NPI) to identify health care providers in all Health Insurance Portability and Accountability Act (HIPAA) standard transactions used in the Medicare Fee-For-Service (FFS) program.
In accordance with the “Guidance on Compliance with the HIPAA NPI Rule,” issued in April 2007, Medicare FFS will be lifting its NPI contingency plan on Friday, May 23, 2008. All health care providers and suppliers who submit claims to Medicare Contractors [Fiscal Intermediaries (FIs), Carriers, A/B Medicare Administrative Contractors (MACs), and DME MACs] must use their NPIs to identify themselves and any other health care providers and suppliers on those claims.
The NPI is a unique 10-digit number that does not carry other information about the health care providers it identifies, such as the State in which they practice or their medical specialty. The NPI must be used in lieu of legacy provider identifiers in HIPAA standard transactions. If a standard transaction is sent to Medicare with a Medicare legacy identifier in any of the provider fields, the transaction will be rejected.
“We have been working with health care providers and their trade and professional organizations for more than two years to get us to this point of one unique number for identification. We are once again strongly urging all health care providers to act now and ensure they have and use their NPI. All Medicare transactions that are sent with a legacy number will be rejected on and after the May 23 deadline,” said Acting Administrator Kerry Weems.
The intent of the NPI is to simplify standard transactions by having health care providers use a single identifier (the NPI) to identify themselves, thus eliminating the need for health care providers to keep track of and use the multiple identifiers that health plans have assigned to them over the years. “The NPI will not only simplify the claims process for providers, it will improve the efficiency of the health care system and help to reduce fraud and abuse,” added Weems.
Over the past several years, CMS has conducted an aggressive outreach campaign to reach and inform Medicare FFS providers, suppliers, State Medicaid Agencies, and others about the NPI requirements. This effort accelerated in recent weeks in response to the approaching deadline and industry comments. Examples of outreach activities include, regular messages through CMS listservs; Medicare Learning Network Matters articles; Web site postings; regular calls with provider associations and clearinghouse groups; messages and announcements at the CMS Provider Open Door Forums; NPI “roundtables” that support nationwide call-ins for questions and answers; messages associated with individual claim submissions; communications with the State Medicaid Agencies to understand their readiness since many Medicare beneficiaries are dual eligibles; and press interviews.
In addition to these efforts, CMS launched a “Legacy-Free Day” exercise on May 7th, where for one day only clearinghouses stripped legacy numbers from Medicare claims and submitted claims with only NPIs. Clearinghouses submit between 60 and 80 percent of Medicare claims. On Legacy-Free Day, Medicare received a large volume of NPI-only claims across the country. Even more encouraging was the fact there were relatively few claim problems on Legacy-Free Day. All of which suggests that, on May 23, the majority of Medicare claims with NPI-only will be processed successfully.
“CMS has received a lot of positive feedback on our communication efforts. Our exercises and activities to date indicate that Medicare FFS is ready for May 23,” said Weems.
The HIPAA was enacted in 1996 to improve the efficiency and effectiveness of the health care system. The Act included a series of “administrative simplification” provisions that required the Department of Health and Human Services to adopt standards for electronic health care transactions and code sets, and identifiers to be used in those transactions. The final rule adopting the NPI as the standard unique health identifier for health care providers was published January 23, 2004, and became effective on May 23, 2005. All HIPAA covered entities had to be in compliance with NPI provisions by May 23, 2007, except for small health plans, which were given an extra year.
The “Guidance on Compliance with the HIPAA NPI Rule” noted above, allowed CMS, on a case-by-case basis, to exercise its enforcement discretion for up to one additional year where covered entities demonstrate that the failure to comply was due to reasonable cause, not willful neglect, and that good faith efforts to comply and, as appropriate, to bring its trading partners into compliance were made. That additional year ends after May 23, 2008.
“CMS has plans in place to expedite resolutions and ensure that providers and suppliers will be paid for treating Medicare beneficiaries, if there are problems that arise on or after May 23. CMS will also monitor all State Medicaid programs for any problems with NPI claims processing,” added Weems. Medicare providers and suppliers who experience claims problems should contact their Medicare contractors. Each contractor has established an NPI Coordination Team to quickly resolve claims processing issues and any related provider and supplier enrollment issues.
For more information about the NPI, please visit www.cms.hhs.gov/NationalProvIdentStand on the CMS Web site. Health care providers can apply for an NPI online at https://nppes.cms.hhs.gov or can call the NPI enumerator to request a paper application at 1-800-465-3203.