Only 20 days left until the National Provider Identifier (NPI) compliance date– do you have your NPI yet?  Covered entities (including health plans, covered health care providers and clearinghouses) across the country are making decisions regarding their need for contingency plans for NPI implementation. It is more important than ever to obtain an NPI as soon as possible and begin testing it on claims, as directed by your health plan. 
 New Compliance Contingency Guidance FAQs
CMS has posted new FAQs related to the previously posted NPI Compliance Contingency Guidance.  Questions include:

To view these FAQs, you should:

Obtain Information on Contingency Plans
CMS strongly urges providers to pay attention to information from the health plans they bill so that they are aware if, and when, a specific health plan announces its own contingency plan.

Reminder – Sharing NPIs
Once providers have received their NPIs, they should share their NPIs with other providers with whom they do business, and with health plans that request their NPIs.  In fact, as outlined in current regulation, providers who are covered entities under HIPAA must share their NPIs with any entities that need them for billing purposes -- including those who need them for designation of ordering or referring physician.   Providers should also consider letting health plans, or institutions for whom they work, share their NPIs for them.
 
Reminder – Enumerating a Group Practice
A group practice that conducts any of the HIPAA standard transactions is a covered healthcare provider (a covered entity under HIPAA) and, as such, must obtain an NPI. The physicians employed by the group practice, on the other hand, are furnishing services at the group office(s) but they are not conducting any of the HIPAA standard transactions (such as submitting claims, checking eligibility and claim status). As such, the physicians would not be covered health care providers and are not required by the NPI Final Rule to obtain NPIs.  However, as the employer, the group could require these physicians to obtain NPIs and use the NPIs to identify them as the rendering providers in the claims that the group submits.  If these physicians prescribe medication, the pharmacies may require their NPIs in the claims that the pharmacies submit to health plans.  Additionally, health plans can require enrolled physicians to obtain NPIs in order to participate in that plan.  Medicare is an example of a health plan with this requirement.

Important Information for Medicare Providers

Medicare Fee-For-Service (FFS) Contingency Plan Announced!
FFS Medicare has announced its contingency plan.  View the associated Change Request at http://www.cms.hhs.gov/transmittals/downloads/R1227CP.pdf, as well as the related MLN Matters article at http://www.cms.hhs.gov/MLNMattersArticles/downloads/MM5595.pdf on the CMS website.  Please note that these materials were recently revised; please be sure to visit the links above for the latest information. 

 

Still Confused?
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 at the CMS NPI page www.cms.hhs.gov/NationalProvIdentStand on the CMS website or visit the OSMA website at www.OKMED.org under the Headline News section.  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.
Getting an NPI is free - not having one can be costly.
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