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NPI contingency plan announced by CMS
'Good faith efforts' acceptable
Health care providers and other covered entities that acted in "good faith" to become compliant with the requirement for a National Provider Identifier can continue to accept legacy numbers through May 23, 2008, one year after the NPI rule takes effect, according to a notice issued recently by the Centers for Medicare & Medicaid Services (CMS).
All entities covered by HIPAA, including providers, health plans, and clearinghouses that process health care transactions using HIPAA format, must implement the 10-digit NPI code.
The CMS contingency plan protects covered entities from enforcement action as long as they continue to pursue "good faith efforts" to meet the NPI requirements, and indicates the Department of Health and Human Services will investigate only when a complaint is filed, as it has for other HIPAA standards.
Answers to frequently asked questions about the contingency plan guidance can be found at http://questions.cms.hhs.gov. The following questions and answers are among recent additions to the FAQs:
Q. I applied for my NPI over the web and haven't received the NPI notification. What should I do?
A. The contact person should first check the computer's SPAM filter to ensure that the NPI notification e-mail has not been routed to SPAM. If the notification is not in the SPAM filter and it has been 15 days since the NPI application was submitted over the web, the health care provider or the contact person should contact the NPI enumerator at (800) 465-3203.
Q. When should a health care provider deactivate its NPI?
A. A health care provider (or the trustee/legal representative of a health care provider) should deactivate its NPI in certain situations, such as retirement or death of an individual, disbandment of an organization, or fraudulent use of the NPI. To deactivate an NPI, a health care provider (or its trustee/legal representative) must complete a CMS-10114 and mail it to the NPI enumerator.
However, the health care provider (or its representative) should be certain that all billing transactions, that is, the settling of all claims with health plans, are completed before submitting the CMS-10114. If all billing transactions are not complete before deactivating an NPI, issues regarding claims payment may arise.
Q. Will I need to change how I submit claims/bill Medicare in order to participate in the Medicare Care Management Performance (MCMP) demonstration?
A. No. Keep in mind that claims must reflect the correct rendering provider, using the appropriate physician identification number (Medicare Provider Identifying Number) or NPI as appropriate) on each line of the claim. Only providers that bill Medicare through a carrier are eligible to participate in the demonstration.