June 2007

New NPI Tip Sheet Available

A new National Provider Identifier (NPI) Tip Sheet based on the Guidance on Compliance with the HIPAA National Provider Identifier (NPI) Rule released April 2, 2007 is available on the Centers for Medicaid & Medicare Services (CMS) Web site. The NPI Tip Sheet emphasizes that the contingency guidance does not give providers an additional year to obtain an NPI. The NPI compliance deadline was May 23, 2007. Any covered entity that is non-compliant and has not implemented a contingency plan is at risk for enforcement action. Providers should review the new NPI Tip Sheet and the guidelines below for additional information.

Guidelines for claims transactions:

• Providers must have and use their NPI.
• Clearinghouses must accept and use NPIs.
• Health plans must accept and send NPIs with claims transactions.

Guidelines for providers:

• Become aware of contingency plans for any health plan they bill. Contingency plans may differ by health plan.
• Become aware that health plans may change or terminate their contingency plans (with actions such as requiring an NPI on claims or other HIPAA transactions) any time before May 23, 2008.
• Work with vendors and clearinghouses with whom they contract to make sure the NPI is being shared with health plans.
• Monitor how and when health plans will be implementing the NPI.
• Become aware of health plans they bill that did not establish a contingency plan because providers are required to use NPIs now. If an NPI is not being used, claims may be rejected or denied.

Reminder: Sharing NPIs
Providers must share their NPIs with other providers they do business with and with health plans that request it. As outlined in current regulation, providers who are covered entities under HIPAA must share their NPIs with any entity that requires an NPI for billing. This includes providers who need an NPI for ordering services or identifying a referring physician. Providers should also consider allowing health plans, or institutions they work for, to share their NPIs for them.

Medicare Fee for Service (FFS) Contingency Plan Announced April 24
View the associated Change Requestand the related MLN Matters (#MM5595) newsletter on the CMS Web site for the latest information.

Additional Information
Information about NPI can be found in the NPI area of the CMS Web site. Providers may apply for an NPI online at the NPPES Web site, or they can call the NPI Enumerator to request a paper application at 1-800-465-3203.

Getting an NPI is free – not having one can be costly.

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June 2007

CMS Publishes the National Plan and Provider Enumeration System (NPPES) Data Dissemination Notice

On May 30, 2007, the Centers for Medicaid & Medicare Services (CMS) published the Data Dissemination Notice in the Federal Register. The final copy of the Notice is posted on the CMS Web site.

This Notice describes CMS policies that certify National Plan and Provider Enumeration System (NPPES) health care provider data will be available to covered entities under the Health Insurance Portability and Accountability Act (HIPAA) and to others.

The NPPES health care provider data, which is required to be disclosed to the public under the Freedom of Information Act (FOIA), will be made publicly available on June 28, 2007, 30 days after the publication date of the Notice. The FOIA-disclosable data will be available to download. Information can be queried from the NPPES database by NPI or provider name. Files will be updated monthly.

The Data Dissemination Notice encourages health care providers with NPIs to review their NPPES data and make any necessary updates or corrections prior to the end of the 30-day period to ensure their information is accurate when disclosed by CMS. (Health care providers who are covered entities under HIPAA are required by regulation to update their NPPES data within 30 days of any change.) The Notice states that providers who need to delete any NPPES data that was not required for an NPI may do so.

Important Information
The PDF version of the Notice that is available on the CMS Web page and the document published in the Federal Register may vary slightly if the editor at the Office of the Federal Register makes minor revisions to it. The official version of the Notice will be the one that is published in the Federal Register.

New Data Dissemination Frequently Asked Questions Available
CMS has posted new FAQs related to the dissemination notice. The questions include:

• Where is the NPPES data dissemination policy conveyed?
• What NPPES data will CMS disclose?
• How will CMS make FOIA-disclosable NPPES data available?
• Is there a charge to obtain the FOIA-disclosable NPPES health care provider data?
• I want FIOA-disclosable data for only the physicians in California and I want the data on a CD. How do I go about having my request fulfilled?
• When will the FOIA-disclosable NPPES health care provider data be available?
• Providers may review these FAQs and other NPI information on the NPI Frequently Asked Questions page on the CMS Web site. To view the most recent FAQs, click the downward arrow (▼) to the right of the “Date Updated” column heading to review all FAQs identified as "New."

Additional Information
More information about NPI can be found in the NPI area of the CMS Web site. Providers may apply for an NPI online at the NPPES Web site, or call the NPI Enumerator to request a paper application at 1-800-465-3203.

Getting an NPI is free - not having one can be costly.

Note:

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