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Background. The Health Insurance Portability and Accountability Act of 1996 (HIPAA) mandated that the Secretary of Health and Human Services adopt a standard unique health identifier for health care providers. On January 23, 2004, the Secretary published a Final Rule that adopted the National Provid
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1. National Provider Identifier
2. Background The Health Insurance Portability and Accountability Act of 1996 (HIPAA) mandated that the Secretary of Health and Human Services adopt a standard unique health identifier for health care providers. On January 23, 2004, the Secretary published a Final Rule that adopted the National Provider Identifier (NPI) as this identifier.
The NPI must be used by covered entities under HIPAA.
The NPI will identify healthcare providers in electronic transactions for which the Secretary has adopted standards (the standard transactions) after the compliance dates. These transactions include claims, eligibility inquiries and responses, claim status inquiries and responses, referrals, and remittance advices.
3. Background, continued The NPI will replace health care provider identifiers that are in use today in standard transactions.
Implementation of the NPI will eliminate the need for health care providers to use different identification numbers to identify themselves when conducting HIPAA standard transactions with multiple health plans.
All health plans (including Medicare, Medicaid, and private health plans) and all health care clearinghouses must accept and use NPIs in standard transactions by May 23, 2007 (small health plans have until May 23, 2008).
After those compliance dates, health care providers will use only their NPIs to identify themselves in standard transactions, where the NPI is required.
4. NPI Principles NPI is not a credentialing program
NPIs are not tied together in the database
NPI is required on standard transactions, optional elsewhere
HIPAA does not govern internal systems
NPI may be used for any lawful purpose
Identifies health care providers or subparts as health care providers in standard transactions
Replaces the use of proprietary and legacy provider identifiers in standard transactions for health care providers and subparts who have been assigned NPIs
5. NPI is 10 digits: 123456789C
PlanID is also 10 digits
C = Check digit
First digit distinguishes between NPI & PlanID
6. Eligibility for an NPI All healthcare providers as defined in 45 CFR 160.103, are eligible to obtain an NPI
Covered healthcare providers (submitting electronic HIPAA transactions) are required to obtain an NPI
Subparts of covered organization health care providers (that conduct any of the standard transactions) are required to obtain an NPI
Eligible providers include: physicians, hospitals, dentists, nurses, physician assistants, licensed social workers, DME suppliers, suppliers related to health care such as prosthetics, pharmacies, pharmacists, group practices, medical students who provide care.
Providers not eligible include: atypical service providers such as taxis, home & vehicle modifiers, administrative agents for providers such as billing services, clearinghouses, repricers.
7. NPI Specifics 10-position identifier (9 plus a check digit in the 10th position). The ISO standard check digit will detect keying and data entry errors.
All numeric. The numeric NPI will facilitate telephone keypad entry-required for telephone base recognition software. For example, some health plans have established telephone key pad verification software to check on a patient’s eligibility for a particular health care service.
Intelligence free NPI. NPI will not contain intelligence about the health care provider’s organization. For example, if an individual health care provider changes their specialty the NPI is not affected and this ensures the lasting nature of the NPI.
8. Specifics, continued Permanent identifier. The NPI is a permanent identifier for the health care provider, except in certain situations, such as a health care provider who does not wish to continue an association with a previously used NPI which has been used fraudulently.
Unique identifier. Safeguards will be established to guard against assigning the same NPI to more than one health care provider or more than one NPI to the same health care provider.
Individual health care provider: Each individual health care provider may receive and use only one NPI.
Death of a Health Care Provider: An NPI is deactivated upon death or dissolution of a health care provider. Safeguards will be established to ensure a deceased health care provider’s NPI is never reissued.
9. An NPI will not… Be assigned to entities that do not meet “health care provider” definition in regulation
Eliminate or replace the provider enrollment processes conducted by health plans
Guarantee reimbursement by any health plan
Convey covered entity status
Assure licensure or credentials
Require a health care provider or a subpart to conduct standard transactions
10. The NPI Timeline Health care providers began applying for NPIs on May 23, 2005
important to apply for NPI before the compliance date of May 2007 because health plans may require you to use your NPI before that date
NPI Implementation deadline is 5/23/07
Small health plans have until 5/23/08 to comply
11. NPI Application Methods
12. Individual Providers vs. Group Practices An individual who is a covered health care provider and is a member of an organizational health care provider is not considered to be a subpart of the organizational health care provider
The individual would receive a Type I-Individual NPI
Only one NPI assigned for an individual
The organizational health care provider would receive a Type II-Organizational NPI
Defined subpart(s) may receive organizational NPI(s)
13. NPI Enumerator Fox Systems, Inc.
Responsible for provider enumeration process using the National Provider and Plan Enumeration System (NPPES)
Handles NPI applications/update forms
The NPPES will not
Link subparts to covered organization health care providers or vice versa
Capture memberships in groups or multiple practice location addresses
Know whether or not a health care provider is a covered entity
14. The National Plan and Provider Enumeration System (NPPES) National Provider System (NPS) is synonymous with NPPES
Developed under CMS contract
Uniquely identifies health care providers and subparts and assigns them NPIs
Sets up and maintains a record for every enumerated health care provider and subpart
Creates reports and output files Ask about the meaning of the first byte of the NPI…
The NPPES is the system – the enumerator administers the NPPES?Ask about the meaning of the first byte of the NPI…
The NPPES is the system – the enumerator administers the NPPES?
15. The NPPES will not… Link subparts to covered organization health care providers or vice versa
Capture memberships in groups
Capture multiple practice location addresses
Know whether or not a health care provider is a covered entity If a provider has multiple locations, can they sub-part themselves?If a provider has multiple locations, can they sub-part themselves?
16. What information must be furnished to obtain an NPI? The minimum data needed to ensure unique identification
Basic and identifying information, certification statement, signatures, contact person
More information will be required if necessary to establish uniqueness
Federal Register contains list of data elements
I do not understand this screen…
NPI Provider Minutes – document sent to the enumerator has all of the data they are to collect and how to determine duplicates, situational elementsI do not understand this screen…
NPI Provider Minutes – document sent to the enumerator has all of the data they are to collect and how to determine duplicates, situational elements
17. Obtaining NPIs (cont.) NPPES uses data on application or in EFI to ensure unique identification
SSN validation, address verification, duplicate check
Edits to detect incomplete and illogical data
If application is OK, health care provider or subpart is notified of NPI
If application is not OK, Enumerator communicates with health care provider or subpart
18. Use of the Taxpayer Identification Number (TIN) TIN established by regulation to identify a taxpayer (SSN, EIN or ITIN)
Required in many standard transactions to identify entities (including health care providers or subparts) as taxpayers
When TIN is to be reported in standard transactions for its regulatory purpose, it must be used.
NPI cannot be used as a substitute for a TIN
19. Use of DEA, CLIA and Mammography Certification Numbers Not considered to be healthcare provider identification numbers
When Number is to be reported for its regulatory purpose, it must be used.
NPI cannot be used as a substitute for a DEA, CLIA or Mammography Certification Number
20. Options for Obtaining NPI Information Four different sources (maybe more…)
NPPES
Provider to Plan/Clearinghouse
Provider to Provider
Plan/Clearinghouse to Plan/Clearinghouse
21. What should you be doing now? Become informed about the NPI, the enumeration process and its implementation
Identify processes/systems that are affected by provider identifiers
Develop enumeration strategy and submit NPI applications
Develop implementation plans (internal, external with trading partners and others)
Educate staff
22. Implementation Activities Check CMS website for updates
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
23. 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
24. CMS NPI Resources www.cms.hhs.gov
regulations
FAQs
Regulations and Outreach Listservs
Outreach materials, announcements
HIPAA Hotline 1-866-282-0659
AskHIPAA@cms.hhs.gov
CMS “NPI” Web site now available