This month’s article was provided by The Coker Group, an SMA approved partner.

• National Provider Identifier Update

  What is the latest information regarding NPI and the NPPES? When does this information go public and what information is exactly going to be released? Is there anything you should be doing?

  The NPI compliance date for all covered entities with the exception of small health plans (a health plan with annual receipts of $5 million or less) was May 23, 2007. Approximately 98% of the estimated 2.3 million health care providers now have NPIs.  Health plans, health care clearinghouses and health care providers are now transitioning to the implementation phase for NPI compliance.  The compliance date for all entities is May 23, 2008.  After those compliance dates, health care providers will use only their NPIs to identify themselves in standard transactions.

  NPPES health care provider data that are disclosable under the Freedom of Information Act (FOIA) will be disclosed to the public by the Centers for Medicare & Medicaid Services (CMS).  In accordance with the e-FOIA Amendments, CMS will have the NPI Registry (query-only database) operational on September 4, 2007 and the downloadable file will be available one week later. 
  CMS extended the period of time in which enumerated health care providers could view their FOIA-disclosable NPPES data and make any edits they felt necessary prior to the initial disclosure of the NPI Registry.  In order to ensure edits were reflected in the NPI Registry when it first becomes operational and in the first downloadable file, health care providers needed to submit their edits no later than Monday, August 20, 2007.  Health care providers who submitted edits on paper needed to ensure that they are mailed in time for receipt by the NPI Enumerator by that date. 
  If those edits were made after August 20th, the initial NPI Registry will not reflect changes. The following are immediate actions for providers to take:

  • Review your NPPES data and make any necessary edits
    • Some data cannot be updated, changed or deleted
    • Document to assist providers is downloadable from: http://www.cms.hhs.gov/NationalProvIdentStand/Downloads/
      NPPES_FOIA_Data%20Elements_062007.pdf
    • The fastest and most efficient way is to use the web-based system
      • Health care providers who applied online have electronic access to the information in their own NPPES records by user identifiers and passwords they select.
      • Allows most health care providers to submit updates to their NPPES data electronically via the Web.
      • https://nppes.cms.hhs.gov
    • Use the paper form
      • Downloadable from http://www.cms.hhs.gov/cmsforms
      • Available from the NPI Enumerator 1-800-465-3203
    • Call NPI Enumerator if assistance is needed.

  Some of the key data elements that are FOIA-Disclosable are:

  • NPI
  • Entity Type Code (1-Individual or 2-Organization)
  • Replacement NPI
  • Provider Name (First Name, Middle Name, Last Name, Prefix, Suffix, Credential(s), OR the Legal Business Name for Organizations)
  • Provider Other Name (First Name, Middle Name, Last Name, OR 'Doing Business As' Name, Former Legal Business Name, Other Name. for Organizations)
  • Provider Business Mailing Address (First line address, Second line address, City, State, Postal Code, and Country Code if outside U.S., Telephone Number, Fax Number)
  • Provider Business Location Address (First line address, Second line address, City, State, Postal Code, and Country Code if outside U.S., Telephone Number, Fax Number)
  • Healthcare Provider Taxonomy Code(s)
  • Other Provider Identifier(s)
  • Other Provider Identifier Type Code
  • Provider Enumeration Date
  • Last Update Date
  • NPI Deactivation Reason Code
  • NPI Deactivation Date
  • NPI Reactivation Date
  • Provider Gender Code
  • Provider License Number
  • Provider License Number State Code
  • Authorized Official Contact Information (First Name, Middle Name, Last Name, Title or Position, Telephone Number)

  Here is a checklist to stay on top of the transition:

  • Check CMS website for updates
  • https://nppes.cms.hhs.gov
  • http://www.cms.hhs.gov
  • Have a contingency plan
  • Watch/ask for instructions/communications from CMS, vendors, health plans and trading partners
  • Determine impact of NPI on contracts, systems, processes, files
  • Identify/resolve issues early

  NPI Resources:

  • WEDI www.wedi.org
  • Named in HIPAA as consulting organization
  • NPI PAG, SNIP NPI listserv, white papers
  • DSMO’s
  • NCPDP, X12, HL7, NUCC, NUBC, DeCC
  • Other professional organizations and associations
  • www.nppes.cms.hhs.gov
  • NPI Enumerator Call Center
  • 800-465-3203