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April 29, 2008

Down to the Wire with National Provider Identifiers

When we all embarked on this journey down the National Provider Identifier (NPI) path in January of 2004, we knew there would be challenges to implementation but thought they would be ironed out before we got to weeks before the mandated implementation date of May 23, 2008.

NPI and Taxonomy Code Problem. The problem that is occurring is that many health plans, including Medicare, cannot properly identify provider sub-parts when utilizing the NPI and a taxonomy code and therefore cannot properly adjudicate the claim. While this is not a major problem now as providers are submitting claims using an NPI and a legacy number; providers that recently switched to only reporting NPI with taxonomy codes (no legacy number) encountered all sorts of rejected claims as the sub-part could not be linked to the NPI.

Efforts to Address Problem. IHA is working with all the various parties and communicating our member concerns on the importance of resolving this issue quickly or providing a contingency plan of utilizing both the NPI and a legacy number for a certain period of time. IHA also is a member of the executive committee of the National Uniform Billing Committee (NUBC) where this issue first surfaced in early April. It was at the April NUBC meeting that some staff of the National Committee on Vital Health Statistics (NCVHS) overheard the issues with regard to the NPI. As NCVHS is the oversight organization named by Congress for reporting on issues with HIPAA implementation, they expressed concern over the substantial problems being encountered so close to the May 23^rd implementation date.

Informational Items for Providers. Given we are down to the wire and the Centers for Medicare and Medicaid Services (CMS) will need to make a decision fairly soon regarding whether or not to implement a contingency plan, the following informational items will be of interest to you:

Solutions and More Challenges. One of the remedies that CMS has suggested is that providers secure NPIs for all of their sub-parts given the challenges encountered in trying to match provider sub-part units with NPI and taxonomy codes.

If a provider opts to go this route to secure additional NPIs, it is incumbent upon the provider per HIPAA regulations, to notify all of their health plans of any NPIs associated with their hospital. In discussing this issue with health plans, they too, are quite concerned if they start getting new NPIs at this late date as they also have to establish a crosswalk from the new NPI to a legacy ID number to make proper payments.

Illinois Medicaid. Illinois Medicaid has requested IHA to remind providers about notifying them if a provider has more than one NPI as most providers have only provided Illinois Medicaid with one hospital NPI. The following is from Jodie Edmonds of the Illinois Department of Healthcare and Family Services:

"The Illinois Department of Healthcare and Family Services has discovered that some hospitals initially only communicated a single NPI to HFS even though the hospital enumerated its subparts for Medicare purposes. If your hospital has more than one NPI, please ensure that all NPIs are shared with HFS so that all numbers are included in HFS' crosswalk.

You can do this by sending an email to Jodie Edmonds, manager of the billing and payment section, at Jodie.Edmonds@illinois.gov. Please include your hospital's name, HFS provider numbers, and associated NPIs."

Keep You Posted. IHA will continue to keep providers posted on the developments with NPI. Meanwhile, IHA encourages you to complete the WEDI NPI Readiness Survey and to alert IHA if you do encounter claims rejections due to using only submitting NPI (no legacy id) on the national "Legacy Free" day on May 7.

Please direct your concerns to Pat Merryweather at pmerryweather@ihastaff.org. Thank you.