National Provider Identifier (NPI)
While Centers for Medicare & Medicate Services (CMS) guidance is clear that May 23, 2007 was the final deadline for covered entities, other than small plans, to comply with HIPAA's NPI provisions; with consideration of ongoing challenges nationally, CMS/OESS outlined a relaxed approach to enforcement of HIPAA's NPI provisions.
“Through May 23, 2008 CMS/OESS will not impose penalties on covered entities that deploy contingency plans if they have made reasonable and diligent efforts to become compliant and, in the case of health plans, to facilitate the compliance of their trading partners.”
With this in mind DES elected to deploy an extension to our NPI contingency plan which allowed for the continued dual use of the NPI for service/rendering providers through February 29, 2008 dates of processing. The contingency period for dual use of the NPI for service/rendering providers has now expired and DES will enforce appropriate full compliance with the NPI provisions for processing on and after 3/1/2008.
The NPI will be numeric. It will be 10 positions in length (9 plus a check-digit in the last position). It will contain no embedded information about the provider. The NPI can be used on paper transactions.
Covered entities must use only the NPI to identify providers in standard transactions (e.g., filing and processing health care claims and other transactions). Legacy provider identification numbers (e.g., BCBS, CHAMPUS, Medicaid number, etc.) will not be permitted. The Taxpayer Identifying Number (EIN) may need to be used for tax purposes.
Health care providers who are covered entities are required to obtain and use NPIs. Health care providers who are not considered covered entities may also apply and be assigned an NPI.
Health care providers will be assigned NPIs upon successful completion of an application form (paper or electronic). The National Provider System (NPS), being built under a CMS contract, will process the applications and updates, ensure the uniqueness of the health care provider, and generate the NPIs.
A single entity, known as the enumerator, and performing under a CMS contract, will operate the National Provider System (NPS). The enumerator will assist health care providers in completing applications and in furnishing updates, and will be responsible for resolving problems and answering questions.
Information about NPI implementation, including information on how to apply for NPIs,are available to the health care industry by CMS.
For further information check the CMS Web site at www.cms.hhs.gov.