NPI Compliance Deadline has arrived

According to the Center for Medicare and Medicaid Services (CMAS) as of May 23rd, any covered entity that is noncompliant, and has not implemented a contingency plan, is at risk for enforcement action. As this guidance pertains to claims transactions, it means that:

• Providers must have and use their NPI;

• Clearinghouses must accept and use NPIs; and

• Health plans must accept and send NPIs in claims transactions.

Providers should be:

• Aware of contingency plans for any health plans they bill. Contingency plans may differ by health plan.

• Aware that health plans may lift their contingency plans (and require an NPI on claims or other HIPAA transactions) any time before May 23, 2008.

• Working with vendors and clearinghouses with whom they contract, to make sure the NPI is being passed to health plans. Paying close attention to how and when health plans will be testing implementation of the NPI.

For those health plans that did not establish a contingency plan, providers are required to use their NPIs now. This means that if you are not using your NPI, your claim may be rejected or denied.

For more information, physicians may wish to access the new tip sheet entitled – “What the Guidance on Compliance with the HIPAA National Provider Identifier (NPI) Rule Means for Health Care Providers at http://www.cms.hhs.gov/NationalProvIdentStand/Downloads/ContingencyTipSheet.pdf 

Again, once providers have received their NPIs, they should share them with other providers with whom they do business, and with health plans that request them. In fact, as outlined in current regulation, providers who are covered entities under HIPAA must share their NPIs with any entities that request them for use in standard transactions -- including those who need to identify ordering or referring physicians/providers. Providers should also consider letting health plans, or institutions for whom they work (e.g. a large hospital system), share their NPIs for them.