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National Provider Identifier (NPI)

NPI Contingency Satus Survey Launched

About Healthcare IT Transition Group

Healthcare IT Transition Group (http://hittransition.com) is a research, analysis and media organization dedicated to improving American healthcare through the widespread adoption of standards-based information technology.

The National Provider Identifier Contingency Status Survey is designed to get a snapshot of what is really happening now - not what plans are in the works or what dates are on the calendar. Researchers are not asking for forward-looking statements. Respondents will NOT be asked to indicate whether they expect to be compliant with the law as of May 23, 2008.

Some Medicare providers have had payments put on indefinite hold, thanks to the implicit complexities of implementing the National Provider Identifier, plus some additional hindrances caused by actions of CMS. Payment delays began in October of 2007, but only for a "small" number of claims, according to CMS spokespersons. But the changes planned for the final push to end NPI contingency suggest that number of claims may grow substantially after May 23. The changes include:

  • Removing legacy IDs (OSCAR, PIN, UPIN, Medicaid IDs, BCBS Numbers, etc.) from Billing, Pay-to and Rendering provider loops
  • Mandating NPIs for all covered entity providers who might appear on the claim (what Medicare refers to as "Secondary Providers" - Referring, Ordering, Operating, Attending, etc.) - and eliminating legacy IDs for these entities as well
  • Mandating NPIs for secondary providers who are not Covered Entities - many of whom do not have NPIs and may actively resist enumerating (for instance, dentists, mental health professionals, retired physicians and others who do not transmit electronic transactions)
  • Mandating NPIs for the identification of providers who may have little or no contact with the provider who originated the service (retail pharmacies, DME suppliers, reference labs, etc.)

This survey is designed to reveal the extent of these and other NPI-related problems for the healthcare industry.

Will CMS again extend the NPI contingency period? Another enforcement delay, or "re-contingency," may be of little help. The problems appear largely to be in Medicare's computer code, not the regulatory code of the NPI Final Rule. To the extent that other payers mimic Medicare's approach, the problems may multiply, even if the fear of enforcement were removed entirely.

The survey is designed to collect numbers and to identify specific problems - or their absence. Many of the questions address specific problems the researchers have identified as key challenges (ending "dual use," secondary providers, un-enumerated providers, etc.).

The survey provides different sequences of questions for providers, payers, clearinghouses and others. Some questions will be common to all respondents. The survey is a streamlined online instrument, designed to be completed in a few minutes. The survey closes at midnight, April 19, 2008.

To take the survey, to request a free copy of the results data or to learn more, visit http://surveys.hittransition.com/npi.