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National Provider Identifier (NPI)

Medicare’s Key NPI Implementation Dates

Medicare’s Key NPI Implementation Dates

There are two key dates remaining for 2008 in Medicare's NPI implementation plan. There is also some confusion as to the difference between the implementation steps for March 1st and May 23rd. The chart below indicates the implementation steps for each date; as well a new column to help further clarify the difference between these two dates.

Implementation Steps
Key Point
March 1, 2008
  • Medicare FFS 837P and CMS-1500 claims must include an NPI in the primary provider fields on the claim (i.e., the billing, pay-to, and rendering provider fields).
  • You may continue to submit NPI/legacy pairs in these fields or submit only your NPI on the claim. You may not submit claims containing only a legacy identifier in the primary provider fields.
  • Failure to submit an NPI in the primary provider fields will result in your claim being rejected or returned as unprocessable.
  • Until further notice, you may continue to include legacy identifiers only for the secondary provider fields.

Claims with only legacy identifiers in the primary provider fields will be rejected.
May 23, 2008
  • In keeping with the Contingency Guidance issued on April 2, 2007, CMS will lift its NPI contingency plan, meaning that only the NPI will be accepted and sent on all HIPAA electronic transactions (837I, 837P, NCPDP, 276/277, 270/271 and 835), paper claims and SPR remittance advice. (Note that this date is one day earlier than that mandated by the National Enforcement Policy)
  • This also includes all secondary provider fields on the 837P and 837I. The reporting of legacy identifiers will result in the rejection of the transaction.
  • CMS will also stop sending legacy identifiers on COB crossover claims at this time.

If the claim contains a legacy identifier in any field, it will be rejected.

May 23rd is approaching quickly - Test NPI-only claims NOW

While Medicare is receiving well over 90% of claims containing an NPI in primary provider fields, there is a very small percent of claims submitted with NPI- only. Until you submit claims with an NPI-only, you will not have a preview of what your experience will be on May 23rd. The time for correcting problems, should there be any, is getting short. CMS urges that ALL Medicare providers test NOW so that problems can be resolved prior to May 23rd. For example, if there is a problem that requires a change in your Medicare enrollment information, you will need to act immediately.

How to test - After Medicare providers have submitted claims containing both NPIs and legacy identifiers and those claims have been paid, Medicare urges these providers to send a small batch of claims now with only the NPI in the primary provider fields. If the results are positive, begin increasing the number of claims in the batch.

(Reminder: For institutional claims, the primary provider fields are the Billing and Pay-to Provider fields. For professional claims, the primary provider fields are the Billing, Pay-to, and Rendering Provider fields. If the Pay-to Provider is the same as the Billing Provider, the Pay-to Provider does not need to be identified.)

Remember, if you test and your claims are processed successfully, you can approach the May 23rd date with confidence. If you do not, you may face unanticipated cash flow problems.