Veterans Health Administration 11 th Annual HIPAA Summit –NPI Update

1. Veterans Health Administration11th Annual HIPAA Summit –NPI Update C. David Mc Daniel Deputy Director, Business Development Michael Wierzbicki Standard Identifiers Component Liaison September 9, 2005

2. The National Provider Identifier • A standard, unique, 10-position, numeric identifier • Maintained by Centers for Medicare and Medicaid Services (CMS) • Required in HIPAA-standard electronic health care transactions • Intended to universally identify trained, licensed providers of health care services and supplies • Individuals (i.e. doctors and other health care practitioners) • Organizations (e.g. hospitals and nursing homes)

3. The National Provider Identifier • Deadline: By May 23, 2007, HIPAA "covered entities" must use NPIs on all HIPAA-standard electronic transactions • Therefore, NPIs are required for • All billable health care practitioners providing health care services to VHA (a HIPAA-covered entity) • VHA organizational providers

4. Implementing the NPI • The Department of Health and Human Services (HHS) contracted with an organization, known as the Enumerator, that receives and processes NPI applications by: • Using the National Plan and Provider Enumeration System (NPPES) to uniquely identify each health care provider; • Answering questions about NPI applications, assignments, and information updates; • Collecting information, via applications and updates, to maintain the NPPES database (which contains NPIs and provider information).

5. VHA’s Implementation of the NPI What is VHA doing about the NPI? • Established an NPI Workgroup consisting of representative from VHA provider and health plan business lines; • Brokered relationships with other federal agencies; • Spreading the word to the provider community; • Actively participating in the Workgroup for Electronic Data Interchange (WEDI) NPI Policy Advisory Group (PAG); and • Preparing for bulk enumeration (enumeration is the process by which providers are assigned NPIs).

6. Enumeration of Individual Providers Enumeration of Organizational Providers Four Critical Processes Now 1 2 # #

7. Preparation of the Revenue Cycle Preparation of Credentialing and Privileging to collect and maintain NPIs Four Critical Processes Now 3 4 # #

8. #1 Enumeration of Individual Providers • Awareness & Support • Distribution & Verification • Authorization,Application, & Enumeration • Re-distribution & Implementation

9. Enumeration of Providers • Designated the VHA Chief Business Office (CBO) as the lead in ensuring that providers can apply for, and receive, NPIs in bulk. • Credentialing & Privileging to maintain enumeration • Worked with VHA’s credentialing & privileging service on a process to receive the necessary provider information and send it to the Enumerator • Received first pass of data in a database, which was created for the compilation of providers’ NPI application information • Will refresh this data closer to the bulk distribution process • Strategized about educating VHA providers and developed NPI educational materials for the field • Participated in CMS’ NPI test program • Identification of billable providers required to obtain an NPI (primarily at medical center and clinic levels, but some exist at lower levels) • Met with VHA’s office of acquisitions to discuss how the NPI will affect contracting (i.e., changes to contracting requirements) • Engaged union involvement to ensure that no difficulties were posed by VHA’s requirement for providers to obtain NPIs

10. #2 Enumeration of Organizational Providers • Identification of level of granularity for sub-parts • Reconciliation with the way in which health care facilities are numbered (VHA-specific and federal tax ID number, etc) • Anticipation of maintaining NPI application data in a dynamic environment

11. Enumeration of Organizational Providers (cont’d) • HIPAA PMO to maintain enumeration of organizational providers • In preparation for enumeration, developed database for storing organizational provider information • Currently accomplished at the medical center and community clinic levels • Verifying the appropriate level of enumeration of VHA subparts

12. 162 VAMCs (per VISN breakdown)

13. 681 CBOCs (per VISN breakdown)

14. 852 Sites (per VISN breakdown)

15. #3 Preparation of Revenue Cycle • Identification of system and software changes needed • Identification of business process changes needed • Internal testing

16. Preparation of EDI Revenue Systems • Project manager identified for Electronic Data Interchange (EDI) Revenue Systems processes, not just internal billing • Preliminary plan to address the changes that are being defined • Expect to be testing these systems with payers by summer 2006 • Anticipate payers will need time to work through back-end issues with elimination of current provider numbers • On target for a May 2007 implementation of NPIs within the billing processes

17. e-IIV More billing opportunities, Cleaner claims OHI, F-STOP Additional insurance data e-Payments Faster payment, Faster AR close-out e-MRA More accurate billing & AR e-Denial Management Enhanced collections HIPAA: Nat'l Provider ID VHA Revenue Cycle Pre-registration Treatment Generate Receive Post Intake Claims & AR Payment Revenue CIDC charge capture e-Claims Plus + e-Pharmacy Claims Faster payment, Drug Utilization Review (DUR)

18. #4 Preparation of Credentialing and Privileging to collect and maintain NPI • Identification of necessary system and software changes • Adding fields for the NPI • Not adding taxonomy codes • Identification of necessary business process changes • Internal testing

19. Scope of Providers • Licensed independent providers • Per data gathered 8/18/05 from Credentialing and Human Resources systems: • 81,649 total providers have begun the credentialing process • 53,466 active providers at some point in the credentialing process • 46,549 appointed providers, credentialing completed

20. Identifying and communicating with trading partners Canvass VHA payer community to understand its needs Assess contract terms to validate NPI organizational outline Communicate with payer partners on phased (legacy, dual, and NPI-only) compliance approaches Software development and NPI Implementation that will not negatively impact the revenue cycle Gather requirements Design software Develop systems Conduct internal testing of interfacing systems and external testing with clearinghouse and payer partners Two More Critical Processes

21. Other NPI Preparation • Drafted NPI official guidance in the form of a directive and handbook • Discussed the NPI on appropriate national VHA calls • Worked with Human Resources to obtain data to be used in bulk enumeration file • Developed internal web site to compile and distribute providers’ NPI application information in preparation for NPI bulk enumeration • Disseminated all approved educational material to the field via the VHA HIPAA PMO web site

22. Expected Issues to Address • Complexity of impact to organizational systems and business processes will be great • Volume of providers to enumerate is significant • Changes to credentialing and privileging process and systems to accommodate NPI must be completed • Union and contracting changes to accommodate a requirement to have, maintain, and use an NPI will require negotiations (both internally and externally) • Some trading partner limitations and complications remain to be fully understood and factored into the overall implementation strategy

23. VHA Implementation Issues • How much effort will be required to integrate the NPI into existing systems? • Bulk enumerating individual and organizational providers with CMS • Will CMS’ system be able to handle VHA’s bulk load? • How far down into VA’s organization do we enumerate organizational providers? • Billing or pay-to provider versus service provider • How do we effectively spread the word about the NPI to all affected employees?

24. Unexpected Issues to Address These factors add to the anticipated complexity of the changes necessary for migrating from legacy numbering systems: • System of Records issues related to Privacy Act requirements • Variables in provider types (licensed VS. non-licensed; billable VS. non-billable; interested in bulk enumeration VS. not interested; etc.) • Communication challenges: reaching all providers who need to hear about the NPI • Misinformation in the industry

25. Misinformation Example Source: Internal Medicine News, July 15, 2005. “The requirement could mean that some physicians who are part of group practices and other arrangements would have multiple NPI numbers.”

26. Industry Call to Action • Begin dialog NOW (or months ago) • Partnerships with provider and plan groups to discuss each other’s needs and anticipated problems • Seek common ground to address some of the largest issues: • Transition from legacy numbering systems • Testing, scheduling, and EDI partnerships • Maintaining revenue flow between plans and providers • Speaking the same language, common interpretation of the Rule and not bogging down into minutia • Learn from the industry’s mistakes in EDI

27. Spirited Discussion