The Health Administration Center (HAC), as a HIPAA compliant health plan, will be ending our NPI Contingency Plan on May 23, 2008. As of May 24, 2008 we will require the NPI in all inbound HIPAA covered transactions received by the HAC or its clearinghouse business associates for medical, dental and pharmacy claims. We will also require the Tax Identification Number (TIN) or Employer Identification Number (EIN) for the entity to be paid in all X12 837 Claim transactions.
HAC NPI Contingency Plan
The Health Administration Center is currently accepting NPIs in electronic transactions received at its clearinghouses for medical, dental and pharmacy transactions. Also include your Tax Identification Number with the entity that will be paid on all electronic 837 claim transactions. On May 24, 2008, the HAC will end it's contingency plan and require the use of the NPI on all inbound transactions.
If you are a HIPAA covered health care provider who electronically bills for services to VA programs, or submits other electronic transactions to us, through our clearinghouses, you need an NPI. NPIs that should be sent include, but are not limited to, rendering, referring and prescriber NPIs.
If you are submitting your claims via the new paper forms UB04, CMS 1500 (08/05) or the ADA J400 form there are fields that allow entry of the NPI. Please include your NPIs on your paper submissions as well as the Tax Identification Number in the appropriate locations.
The Health Insurance Portability and Accountability Act of 1996 (HIPAA) requires the adoption of a standard unique identifier for providers. The National Provider Identifier (NPI) Final Rule was issued on January 23, 2004 and adopted the NPI as this standard. The compliance date for implementation of this new identifier is May 23, 2007.
The NPI is a 10 digit intelligence free numeric identifier. Intelligence free means that the numbers do not carry information about health care providers, such as the state they practice or the provider type or specialization. The NPI will replace other health care provider identifiers used in HIPAA standard electronic transaction that they conduct with health plans. Those transactions include but are not limited to the electronic claim (837), eligibility inquiry and response (270/271), claim status inquiry and response (276/277) payment and remittance advice (835), prior authorization/referral (278) and all coordination of benefit transactions. Some examples of the identifiers that will be replaced by the NPI are: Medicare legacy IDs, UPIN, BCBS numbers and OSCAR. The NPI does not replace for the Tax Identification Number (TIN) also needed to process and pay claims.
Health care providers such as physicians, dentists, opticians, chiropractors, medical equipment suppliers, hospitals, pharmacies and other providers of medical services are eligible for NPI's and can apply for an NPI. Health care providers are individuals or organizations that render healthcare. All health care providers that are HIPAA covered entities, whether they are individuals or organizations must obtain an NPI to identify themselves in all HIPAA covered electronic transactions.
Providers can apply for an NPI in one of three ways:
Regardless of how you obtain your NPI, it is important that you retain the notification document that NPPES sends to you that contains your NPI. You will need to share this information with other health care partners who may provide electronic billing services to you or your organization.
Once you obtain your NPI, it is estimated that it will take 120 days to do the remaining work to use it. This includes working on your internal billing systems, coordinating with billing services, software vendors, and clearinghouses, testing with payers. As outlined in the Federal Regulation, (The Health Insurance Portability and Accountability Act of 1996 (HIPAA)) you must also share their NPI with other providers, health plans, clearinghouses, and any entity that may need it for billing purposes. If you delay applying for your NPI, you risk your cash flow and that of your health care partners as well.
To date over 1.6 million providers have obtained their NPI from the National Plan and Provider Enumeration System (NPPES). A recent survey of the health care industry, conducted by the Workgroup for Electronic Date Interchange (WEDI), indicates that providers should have already applied for an NPI and be focusing on implementation with health plans and clearinghouses. If you have not obtained your NPI, you should do so immediately so that you can begin implementation and testing. Your NPI is critical for health plans and health care clearinghouses to aid in the transition to the NPI by the implementation date of May 23, 2007.
If you need more information and/or education on the NPI, it can be found at the CMS NPI page at www.cms.hhs.gov/NationalProvidentStand on the CMS website.